- The case concerned whether tax authorities could make extraordinary tax assessments due to at least gross negligence by the taxpayer, 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 the tax increases made by the Tax Agency were materially correct.
- The court found the taxpayer 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 taxpayer’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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