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Supreme Court decides that marketing activities did not constitute compensable sevices Jens Wittendorff

By: Wittendorff, Jens.
Material type: ArticleArticlePublisher: 2019Subject(s): PRECIOS DE TRANSFERENCIA | EMPRESAS MULTINACIONALES | DINAMARCA In: International Transfer Pricing Journal v. 26, n. 3, May/June 2019 Summary: 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.
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Disponible únicamente en formato electrónico en la Biblioteca del IEF.

Resumen.

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.

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