Danish tax cases and litigation.
Representation from the first Tax Agency enquiry through administrative appeal, Landsskatteretten and court proceedings.
A Danish tax case is won or lost on facts, timing and framing as much as on the law. The first response to the Tax Agency often determines how the authority understands the matter for the rest of the case. By the time a final decision has been issued, the evidentiary record may already be difficult to repair.
Moore Law represents private clients, founders, executives and companies in Danish tax matters from the first enquiry through appeal and litigation. The work includes evidence strategy, written submissions, appeal drafting, cost-recovery handling and coordination with foreign tax or corporate advisers where the matter is cross-border.
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The ordinary deadline for appealing a Danish tax decision is generally three months from receipt. The deadline and correct appeal route must be checked immediately.
A tax case should be framed before it is fought.
Many taxpayers respond too quickly to the first letter and too late to the final decision. The better approach is to treat every stage as part of one evidentiary record.
At the Tax Agency stage, the task is to make the facts legible. At the appeal stage, the task is to show why the decision is wrong. At Landsskatteretten or in court, the task is to present the law, evidence and procedural history in a form that can be decided.
The case should not merely be answered. It should be built.
What to do when the Tax Agency writes.
- Identify whether the letter is a request, proposal, decision or procedural notice.
- Confirm the deadline.
- Preserve the envelope, digital-post timestamp or receipt evidence.
- Do not answer informally on complex facts.
- Gather the relevant tax returns, assessments, correspondence and supporting documents.
- Identify whether other jurisdictions, companies or family members are affected.
- Check whether there is a parallel VAT, employer tax, corporate tax, property, exit-tax or criminal-risk dimension.
- Decide whether the matter can be resolved at agency level or should be prepared for appeal.
A rushed answer can become the authority’s favourite exhibit.
Stages of representation.
Tax Agency stage
Responses to information requests, audit letters and proposed assessments. The focus is factual clarity, supporting evidence and legal framing before a final decision is issued.
Appeal to Skatteankestyrelsen
Preparation of formal appeals, grounds of appeal, evidence bundle and procedural correspondence. The correct appeal route and deadline are confirmed at the outset.
Landsskatteretten
Substantive appeal work before the National Tax Court, including legal argument, oral hearing preparation and the management of evidentiary weaknesses.
Ordinary courts
Where the matter proceeds beyond the administrative system, Moore Law coordinates with court-admitted counsel where required and remains principal tax adviser.
Cost recovery
Handling of cost-recovery claims under the Danish tax appeal framework, including eligible expenses and the degree-of-success analysis.
Settlement and correction
Where appropriate, advice on whether the matter can be resolved by agreement, correction, reopening, reassessment or alternative procedural route.
Types of tax cases.
- Tax residency and emigration disputes
- Exit tax on shares, options and founder interests
- Cross-border income and source disputes
- Share disposals, earn-outs and capital gains
- Dividend, withholding and beneficial-owner issues
- Corporate tax and group restructuring
- Transfer pricing and related-party flows
- Property and valuation disputes
- VAT and indirect tax where connected to wider commercial matters
- Procedural and administrative-law issues
- Cost-recovery disputes
Costs, appeal fee and reimbursement.
Danish tax appeals are unusual because the cost-recovery framework can materially change the economics of pursuing a case. As a starting point, eligible expert-adviser costs may qualify for reimbursement, with the level depending on the statutory framework, the party, the type of matter, the stage and the degree of success.
The ordinary deadline for appealing a Danish tax decision is generally three months from receipt. The Danish Tax Agency’s 2026 fee table shows a complaint fee of DKK 1,300 for complaints to Landsskatteretten and Skatteankestyrelsen. The specific decision and appeal route must always be checked.
A strong tax case can still be lost if the deadline is missed or the appeal is framed incorrectly.
Common questions.
When should I contact Moore Law about a tax case?
As soon as the Tax Agency writes, or immediately after a decision is received. The earlier the facts and evidence are organised, the stronger the case usually becomes.
How long do I have to appeal a Danish tax decision?
The ordinary deadline is generally three months from receipt of the decision, but the exact deadline and appeal route must be checked against the decision and the applicable rules.
Can legal costs be reimbursed?
Possibly. Danish tax appeal and litigation cost reimbursement depends on eligible costs, the type of matter, the party, the stage and the degree of success. It should be assessed case by case.
Should I answer the Tax Agency myself first?
For simple factual matters, that may be appropriate. For tax residence, exit tax, shares, cross-border income, company structures or large assessments, the first answer should usually be reviewed before it is sent.
Can the case be resolved before appeal?
Often yes. Many matters can be resolved at agency level if the facts are presented clearly and the legal issue is framed correctly.
Related: Binding rulings · Tax residency & exit tax · Denmark–UAE relocation · International taxation · Dispute resolution · Contact the Danish practice.
Danish tax appeal deadlines, fees and cost-recovery rules should always be checked against current official sources before action is taken.
- Danish Tax Agency — How to complain
- Danish legal guidance — Tax appeal deadline
- Danish Ministry of Taxation — 2026 fee table
- Danish legal guidance — Degree of success for cost recovery
- Danish legal guidance — Eligible cost-recovery expenses
External government and institutional sources. Programme figures and regulatory positions should be verified against these before they are relied upon.