Degerstrøm Global Tax & Sustainability

International tax advisory for energy and resources groups navigating cross-border structures, transfer pricing, and minimum tax obligations.

Consultoria tributária internacional para grupos de energia e recursos que navegam estruturas transfronteiriças, preços de transferência e obrigações de imposto mínimo.

We help senior finance teams identify hidden exposures early, before they become costly problems.

Ajudamos equipes sênior de finanças a identificar exposições ocultas cedo, antes que se tornem problemas caros.

Designed for CFOs, Tax Directors, Finance Directors, and General Counsel who need clear senior-level advice on cross-border risk.

Atuação direta com CFOs, Diretores Tributários, Diretores Financeiros e Conselhos de Administração.

Based in Norway and focused on cross-border matters involving the Nordics, Europe, the Middle East, and selected African jurisdictions.

Assessoria a grupos empresariais na Europa, América Latina, Oriente Médio e África.

Request a diagnostic About DGTS

The questions we answer

The kinds of problems finance teams need to address before they reach the audit stage.

Tax structure

Will Pillar Two neutralise the tax efficiency of your current cross-border structure?

Transfer pricing

Is your TP documentation aligned with how your business actually operates — or how it operated three years ago?

Carbon exposure

Could CBAM increase your import cost exposure in ways your current pricing model does not account for?

PE risk

Are cross-border activities creating unintended permanent establishment exposure in jurisdictions you are not currently filing in?

Core services

Three practice areas. One integrated view.

We do not offer a long list of technical services. We offer three practice areas designed to work together — because the risk to your business rarely lives in only one of them.

01 —

International Tax & Cross-Border Structuring

We review existing tax structures, financing arrangements, and international operations — identify exposure — and design defensible, efficient structures under evolving global rules.

Pillar TwoTransfer pricingPE analysisM&ACross-border structuring

02 —

Carbon Regulation & Tax Interaction

We map your exposure to mandatory carbon frameworks — CSRD, EU ETS, CBAM — and connect those obligations directly to your tax and transfer pricing architecture. The risk is not carbon compliance in isolation; it is where carbon rules create unexpected tax cost.

CBAMEU ETSCCUS tax planningCarbon-tax interactionCSRD

03 —

Strategic Risk Diagnostics

A structured review of how your tax, carbon, transfer pricing and regulatory positions interact — surfacing hidden costs and inefficiencies that arise when advised in isolation.

Cross-border diagnosticTax-carbon interactionInvestment structure review

Who we work with

Clients where cross-border complexity is structural, not occasional.

DGTS works with organisations whose tax, carbon, and regulatory exposure spans multiple jurisdictions simultaneously — and where the cost of fragmented or siloed advice is material.

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Energy & Resources Companies

Upstream, midstream, downstream operators — cross-border exposure, CCUS decisions, energy-specific tax regime complexity.

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Industrial & Manufacturing Groups

Manufacturers with CBAM liability, transfer pricing scrutiny, and cross-border supply chain risk.

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Infrastructure Investors

Funds and operators with multi-jurisdiction financing, CSRD obligations, and Pillar Two exposure across portfolio.

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Multinationals with Nordic Operations

International groups entering or restructuring in Norway, Sweden, Finland, Denmark — where local rules interact with treaty networks and EU frameworks.

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Cross-Border Mid-Market Groups

Owner-managed or PE-backed businesses crossing jurisdictions for the first time — where PE, WHT, and transfer pricing obligations are often unmanaged.

Por que a DGTS

What you get when you work directly with DGTS.

Direct access to the principal adviser

Every engagement is led by Fred Kenneth Degerstrøm from start to finish.

Specialist tax focus

Cross-border tax, transfer pricing, and Pillar Two exclusively — integrating carbon compliance only where it affects tax cost.

Independent — no audit conflicts

DGTS does not perform statutory audits. Advice is independent of any audit relationship, with no commercial constraint on what gets raised or recommended.

Senior-level expertise, full accountability

ADIT-qualified adviser and Norway Correspondent for IBFD. Primary focus on Norway, the Nordic region, and the wider EEA, with active cross-border advisory across the EU, UK, Middle East, and Africa.

Typical issues we encounter

Where separate disciplines leave the most important risks undetected.

The following reflect the type of cross-border situations DGTS is engaged to analyse.

Carbon & Transfer Pricing

CBAM exposure hidden inside a transfer pricing structure

An industrial group had optimised its intercompany pricing to minimise tax in high-rate jurisdictions. The same pricing arrangement, examined under CBAM rules, produced a carbon cost liability significantly higher than a market-price calculation — an exposure the tax team had not modelled, because the carbon team was not part of the TP review.

The issue

Transfer pricing and carbon compliance were designed independently. When they interact, the optimisation in one framework can create unintended cost in the other.

Pillar Two & IP structuring

Global minimum tax neutralising an existing IP structure

A multinational had structured its IP holding in a low-tax jurisdiction under rules that applied at the time of implementation. Under Pillar Two, the expected tax benefit was substantially eliminated — but the compliance costs and substance requirements of maintaining the structure remained fully intact, creating a net-negative position.

The issue

Structures designed before Pillar Two may now carry cost without delivering benefit. Identifying that position requires modelling the GloBE rules across all jurisdictions simultaneously — not jurisdiction by jurisdiction.

Recent international tax developments

Selected reports prepared as Norway Correspondent for IBFD.

2026

Norway Opens Consultation on Public Country-by-Country Tax Reporting

Analysis of Norway's proposed implementation of EU Directive 2021/2101, including scope, thresholds, and the interaction with confidential BEPS country-by-country reporting already in force.

2026

Norway Consults on Pillar Two Safe Harbour Amendments

Analysis of proposed amendments implementing the OECD's January 2026 Administrative Guidance, including four new Safe Harbour regimes and an extension of the Transitional CbCR Safe Harbour.

Emerging Issues & Research

What's Next in International Tax

The OECD reacts to market developments. We anticipate them. Our research explores the tax implications of AI, regulatory evolution, and cross-border investment trends before they become crises.

DGTS Insights & Research

Systematic analysis of emerging issues in international tax. Each paper is grounded in OECD doctrine, sector expertise, and real-world transaction structures.

DGTS Insight

AI, Value Creation and Taxing Rights

June 2026

Explores how artificial intelligence systems create value, where that value accrues under current PE and transfer pricing doctrine, and why OECD nexus rules will need to evolve.

Author: Fred Kenneth Degerstrøm, ADIT, Founder DGTS. International Tax Adviser specializing in cross-border structuring, transfer pricing, permanent establishment, Pillar Two and energy sector taxation. Norway Correspondent for IBFD.

Download paper (PDF) →

How we engage

Four engagement types. Most begin with a diagnostic.

Fixed scope. Defined deliverable. No open-ended commitment.

Diagnostic review

A structured review of where your tax, carbon, and regulatory positions interact and create exposure. Timeline and scope set around your organisation's structure and the jurisdictions involved. Deliverable: cross-border risk matrix, exposure map, and prioritised action plan. Entry point for most engagements.

Most diagnostic engagements range from €10,000–15,000, with larger multi-jurisdiction reviews scoped separately based on complexity.

Download a sample diagnostic deliverable (PDF) →

Regulatory readiness review

Strategic advisory on a specific obligation — Pillar Two, transfer pricing exposure, CBAM, EU ETS, or CSRD — identifying where your position stands and what it requires before it becomes an audit or compliance event.

Strategic advisory retainer

Ongoing access as regulatory conditions evolve. Monthly monitoring, quarterly review, and direct access for time-sensitive matters.

Transaction support

Tax, TP, and carbon regulatory due diligence for M&A, restructuring, or cross-border investment — integrated from the first term sheet.

About DGTS

International tax advisory, built for cross-border complexity.

Degerstrøm Global Tax & Sustainability was founded on the observation that financial risk accumulates in the gaps between specialist disciplines — where international tax rules, carbon compliance, and cross-border reporting obligations converge. We focus on energy, infrastructure, and industrial groups operating across multiple jurisdictions, where that exposure cannot be managed in isolation.

Fred Kenneth Degerstrøm — Founding Principal

International Tax Adviser — Energy, Resources & Cross-Border Structuring

ADIT — Energy & Resources MSc International Taxation, BI Norwegian Business School IBFD Norwegian Tax Correspondent International Tax Affiliate, CIOT Former CEO & CFO — 20+ years international business, finance & tax

Advises energy operators, infrastructure groups, and multinationals on cross-border tax structuring, Pillar Two, transfer pricing, and carbon compliance — helping clients avoid unnecessary tax leakage, regulatory costs, and audit exposure before they materialise. Every engagement is led directly by Fred Kenneth Degerstrøm. Clients work with the principal adviser throughout — no intermediary layer.

Get in touch

Start with a diagnostic.

Comece com um diagnóstico.

The starting point is typically a structured diagnostic review: a focused mapping of where cross-border tax, carbon, and regulatory positions create interaction risk, followed by a clear and prioritised basis for next steps.

Request a diagnostic review