Extraordinary VAT Assessment: Gross Negligence and Six-Month Notice Period Compliance Disputed

• The case concerned whether tax authorities could make extraordinary tax assessments due to at least gross negligence by the plaintiff, under section 32(1)(3) of the Tax Administration Act.
• The court also considered whether the tax authorities complied with the 6-month notification deadline in section 32(2) of the Act.
• Both parties agreed that the tax increases made by the Tax Agency were materially correct.
• The court found the plaintiff acted with at least gross negligence by not reporting according to their own accounts, justifying extraordinary reassessment.
• The court determined the Tax Agency only became aware of the relevant circumstances upon receiving the plaintiff’s accounting information, enabling a qualified assessment of VAT reporting.

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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