International tax law

International tax law advisory encompasses the analysis, structuring, and optimization of cross-border transactions and investments in line with complex and evolving global tax regulations. The service includes the interpretation and application of double tax treaties, transfer pricing rules, and anti-avoidance measures to support tax-efficient and compliant business models. It is designed to help multinational enterprises manage tax risks, align tax strategies with business objectives, and respond effectively to regulatory and legislative changes in multiple jurisdictions. Submit a request

International Tax Structuring for Denmark-Based Groups

International tax advisory dedicated to the Danish market is driven by the need to reconcile increasingly complex global tax rules with the distinctive characteristics of Denmark’s open, innovation‑oriented economy. Read more.

Case study

Cross-Border Restructuring for a Tech Scale-Up

A rapidly growing software-as-a-service group from the technology sector had expanded into eight countries within four years. The founders focused on product and sales, w...More +

International Tax Optimization for a Food Producer

A regional food manufacturing group specializing in packaged snacks had grown from a domestic producer into a supplier for several neighboring countries. The company oper...More +

Global Tax Strategy for an Industrial Equipment Group

An industrial equipment supplier specializing in large-scale machinery for energy and infrastructure projects operated in more than twenty countries through a mix of subs...More +

International Tax Compliance for an E-Commerce Retailer

An online retailer in the consumer goods sector had built a successful business by selling through its own website and multiple marketplaces across Europe, North America ...More +

What we provide

Cross-Border Structuring

We design and optimize cross-border holding, financing, and operating structures to achieve tax efficiency while managing legal and reputational risk.

Global Compliance

We coordinate and manage worldwide corporate tax compliance, ensuring timely and accurate filings aligned with local and international regulations.

Transfer Pricing

We develop, document, and defend transfer pricing policies that reflect value creation across jurisdictions and withstand tax authority scrutiny.

Treaty Optimization

We analyze and leverage double tax treaties and EU directives to minimize double taxation and enhance cross-border cash repatriation.

M&A Tax

We support international mergers, acquisitions, and restructurings by conducting tax due diligence and structuring deals to optimize post-transaction outcomes.

BEPS Advisory

We help clients interpret and implement OECD BEPS and Pillar Two rules, aligning their tax models with evolving global standards.

Controversy Management

We represent clients in cross-border tax audits, disputes, and mutual agreement procedures, negotiating with authorities to resolve complex issues.

Tax Governance

We design and implement global tax governance, risk management, and reporting frameworks that support transparency and ESG expectations.

How International Tax Law Can Accelerate a Sustainable Future

International tax law, when approached strategically, can become a powerful lever for a more sustainable and climate‑conscious global economy. A consulting firm that advises on cross‑border taxation does not only optimize effective tax rates; it can ...

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How can we support you?

International tax law support helps organizations navigate complex cross‑border rules, manage risk, and optimize global effective tax rates. The following areas illustrate how a leading consulting firm can assist in structuring international operations, ensuring compliance, and resolving disputes with tax authorities worldwide.

Cross‑border structuring and business model optimization

Radner advises on the design and implementation of cross‑border structures that align tax efficiency with commercial substance and regulatory expectations. Support typically covers the choice of holding, financing, and intellectual property locations, taking into account treaty networks and anti‑avoidance rules. Particular attention is paid to economic substance, governance, and documentation, so that structures remain defensible in tax audits. Assistance is also provided in assessing the tax impact of reorganizations, supply‑chain changes, and market expansions. The objective is to achieve a sustainable global effective tax rate while preserving operational flexibility and reputational integrity. Engagements are tailored to the client’s industry, risk appetite, and long‑term strategic goals.

International tax compliance, reporting, and governance

We support clients in meeting international tax compliance obligations across multiple jurisdictions in a consistent and controlled manner. This includes coordination of corporate income tax filings, withholding tax returns, and information reporting such as country‑by‑country reports and other transparency requirements. Particular focus is placed on aligning tax data, systems, and processes so that management has reliable visibility over global tax positions. Assistance is also provided in designing tax governance frameworks, policies, and internal controls that satisfy expectations of boards, regulators, and investors. The aim is to reduce the risk of penalties, double taxation, and reputational damage arising from non‑compliance or inconsistent positions. Ongoing monitoring of legislative and regulatory changes helps organizations adapt their compliance approach before new rules take effect.

Transfer pricing and value chain alignment

Radner supports the design and defense of transfer pricing models that reflect how value is created across the global value chain. Services typically include functional and risk analyses, benchmarking studies, and the preparation of compliant transfer pricing documentation. Particular emphasis is placed on aligning intercompany pricing with evolving international standards, including OECD guidance and local country rules. Assistance is also provided in implementing practical policies, intercompany agreements, and systems to ensure that pricing is applied consistently in day‑to‑day operations. Where appropriate, advance pricing agreements and cooperative arrangements with tax authorities are explored to provide greater certainty. The overall goal is to manage transfer pricing risk while supporting commercial objectives and operational realities.

Tax controversy, dispute resolution, and treaty relief

We assist clients in managing international tax disputes from initial audit inquiries through to litigation, mutual agreement procedures, and alternative dispute resolution. Support covers responding to information requests, preparing technical position papers, and engaging with tax authorities in a structured and strategic manner. Particular attention is given to cases involving double taxation, permanent establishment challenges, transfer pricing adjustments, and denial of treaty benefits. Assistance is also provided in pursuing treaty relief, foreign tax credit claims, and other mechanisms to mitigate economic double taxation. Where possible, cooperative compliance and early engagement approaches are used to resolve issues efficiently and preserve relationships with authorities. The focus is on achieving robust, sustainable outcomes while minimizing disruption to business operations and cash flow.

Why choose us?

Cross-border mastery

We combine deep international tax expertise with a precise understanding of how Danish regulations interact with cross-border structures. We translate complex multi-jurisdictional rules into clear, actionable strategies that protect our clients from unexpected tax and compliance risks.

Business-first approach

We design international tax solutions starting from our clients’ commercial goals, not from abstract legal theory. We align tax structures with real business operations, ensuring that every recommendation is both legally robust and practically feasible in day-to-day management.

Hands-on execution

We do not stop at written opinions; we actively guide implementation, from structuring transactions to coordinating with foreign advisors and Danish authorities. We stay involved throughout the lifecycle of a project, continuously monitoring regulatory changes and adapting structures before they become a problem.

Contact

Need more information? Contact us.