Appeals against decisions of the Danish Tax Agency (SKAT)
If you receive a decision from the Danish Tax Agency with which you disagree, you have the option of having it reviewed through the administrative appeals system or by the courts. Many taxpayers are not aware that an appeal can often be pursued with limited financial risk, as cost reimbursement may be available.
Cost reimbursement means that, as a general rule, you may have your expenses for professional assistance covered:
100%, if you succeed fully or to a significant extent
50%, if you do not succeed
This makes it possible in many cases to file an appeal without having to bear the full costs yourself.
Which decisions can be appealed?
The Danish Tax Agency and its subordinate authorities issue a large number of decisions each year that may have significant implications for individuals and businesses. These may include, for example:
Amendments to annual tax assessments or tax returns
Increases in income or duty bases
Responses to requests for binding rulings
Decisions in debt collection cases
Refusals of access to documents or failure to provide information
If you believe that a decision is based on incorrect grounds or insufficient documentation, it may be relevant to file an appeal. Previous studies by the Danish National Audit Office have indicated that many tax decisions may be based on an insufficient factual basis. This underlines the importance of assessing whether there are grounds for appeal.
Where should the appeal be submitted?
A decision from the Danish Tax Agency is an administrative decision, and appeals are therefore submitted to the Danish Tax Appeals Agency, which acts as the gateway to the administrative appeal bodies.
The Danish Tax Appeals Agency refers the case for consideration to, for example:
The Tax Appeals Board
The National Tax Tribunal
The Motor Appeals Board
The Valuation Appeals Boards
Time limits, payment and fees
As a general rule, the deadline for filing an appeal is 3 months from receipt of the decision.
It is possible to obtain a deferral of payment, meaning that payment of the disputed tax may be postponed while your appeal is being processed. You will therefore normally not be required to pay the amount until a final decision has been made.
At the same time, a fee must be paid when submitting the appeal. As of 1 January 2026, the fee amounts to DKK 1,300. However, there is no fee for appeals concerning debt collection cases and access to documents.
Possibility of court proceedings against the Danish Tax Agency
If you do not succeed in the administrative appeals system, the case may subsequently be brought before the courts.
Court proceedings differ from administrative appeals in that full evidentiary proceedings are permitted, including:
Party statements
Witness examinations
Expert evidence
Court proceedings may therefore be relevant in cases where there is disagreement as to facts or evidence.
Court review differs from administrative appeals in that full evidentiary proceedings are available before the courts. This includes, among other things, the possibility of giving party statements and calling witnesses, which is generally not possible during administrative proceedings.
However, it should be noted that court proceedings involve a financial risk, as the losing party will generally be ordered to pay the legal costs of the opposing party. Cost reimbursement may, however, usually be obtained, meaning that up to 50% of eligible costs may be covered even if the case is lost.
Cost reimbursement – have your expenses covered
Cost reimbursement applies both in administrative appeal bodies and in court proceedings.
You may obtain reimbursement for, among other things:
Legal and advisory costs
Costs of expert evidence
Court fees
Any awarded legal costs
Other direct costs related to the appeal
Accordingly, a tax case can in many instances be pursued with limited financial risk, particularly when handled with assistance from legal professionals or other expert advisers, where the cost level is often lower than for traditional legal representation.
We can assist you
Aya Law assists with the assessment and handling of appeals against the Danish Tax Agency and collaborates with specialised tax lawyers who can take the case further if it becomes necessary to bring it before the courts.
You are welcome to contact us for an initial, non-binding assessment of your case.