Denial of Deduction for Purchase VAT and Operating Expenses, Disguised Dividends, Extraordinary Reopening of Case

• Dispute over deduction for purchase VAT and operating expenses, disguised dividends, extraordinary reopening
• H1’s right to deduction for purchase VAT and operating expenses in 2011-2014 was questioned
• Capital owners of the company were also being taxed for disguised dividends
• Tax authorities had the right to reopen the tax assessment due to unusual circumstances
• Court found that H1 did not prove that work was done by claimed subcontractor
• Payments for invoices were considered as disguised dividends to capital owners
• Capital owners were found to have shown gross negligence in the circumstances of the payments
• Tax authorities were found to have met the deadline for reaction

Source: info.skat.dk

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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