The Significance of Corporate Losses in Transfer Pricing – The Danish Supreme Court Ruling in the Maersk Oil/Total Energies case

On 6 September 2023, the Danish Supreme Court delivered its ruling in the largest Danish transfer pricing case to date. In addition to its considerable adjustments, the ruling has been a spectacular addition to a decade-long development in the Danish transfer pricing regulation due to the handling of corporate losses, discretionary assessments and aggregated assessments of individual transactions.