In 2012, the tax authorities increased the taxable income for the income years 2006-2008 for two companies in the former A. P. Møller – Mærsk Group. P. Moller – Maersk Group. The taxable income was thus increased for the former Mærsk Olie og Gas A/S (MOGAS), which was taken over by Total S.A. in 2018, and for A.P. Møller – Mærsk A/S (APMM), which was the management company in the joint taxation with, among others, MOGAS. As grounds for the increases, the tax authorities referred to the fact that intra-group transactions had taken place between MOGAS and the company’s subsidiaries, Mærsk Olie Algeriet A/S and Maersk Oil Qatar A/S, which did not fulfil the tax legislation’s rules that transactions between group companies must be priced in accordance with what could have been achieved if the transactions had been concluded between independent parties (arm’s length terms). The assessment of additional income concerned three issues. Firstly, prior to the establishment of the ... Read more