Tax Consultancy Services - Framework Agreement On Tax Advice To Atp. Tendering A Framework Agreement On Current Tax Advice To Atp. Atp Is An Independent, Self -Governing Institution That, As A Public Law Body, Is Subject To A Number Of Public Law Rules. Atp Is Also A Financial Company Under The Supervision Of The Danish Fsa. The Supplier Must - At Atps Ongoing Needs - Provide Tax Advice To Atp. Atps Needs Are Especially In The Following Areas: A) Investments In Infrastructure, Natural Resources, Energy, Credit And Private Equity. The Counseling Need Includes Traditional Tax Due Dilontence When Making New Investments But Is Particularly Aimed At Issues Related To Investment Structure Such As Source Taxation, Permanent Establishment, Substance Criteria, Qualifying Foreign Investment Units In Accordance With Danish Tax Rules And Tax Policy Matters. The Counseling Need Relates To Both Making New Investments, Divestment And Ongoing Monitoring Of Investments (Hereafter The Investment Area). (B) Recovery Of Withholding Taxes On Especially Listed Shares In Complex Cases Where Atps Custodian Can Not Assist With Returning, And Applications For Exemptions For Taxation Abroad. Relief For Foreign Taxes (Hereinafter Pension Return Tax). D) Compliance Conditions, Including In Relation To The Minimum Taxation Act, Dac6, Fatca, Crs, Land-For-Land Reporting And Transfer Pricing.E) Vat And Tax Relations (Hereinafter Vat And Taxes). Statements Of Tax Consequences, Tax Amounts And Reporting Tax Returns To The Extent That Atp May Need This. The Need For External Tax Advice Will Often Mean That The External Assistance Consists Of Highly Specialized Competencies In The Various Disciplines.
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