Supreme Court Decides That Marketing Activities Did Not Constitute Compensable Services

Journal
Wittendorff, J.
Denmark
International Transfer Pricing Journal 2019 (Volume 26), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The Danish Supreme Court has decided that marketing activities performed by Microsoft Denmark did not constitute a compensable service transaction towards a US group company and that the tax authorities were not entitled to make an estimated tax assessment because proper transfer pricing documentation was presented before the tax assessment was made.