Denmark Tax Agency Clarifies VAT Liability, Deductions Regarding Advance Invoicing of Services Between Group-Affiliated Companies

Nov. 6, 2025, 5:00 AM UTC

The Danish Customs and Tax Administration Nov. 3 posted online City Court Decision No. SKM2025.615.BR, clarifying VAT liability and deduction rights regarding advance invoicing of services between group-affiliated companies. The taxpayers, two group-affiliated companies, claimed that VAT liability and deduction rights arose at the time of advance invoicing for services provided by one company to the other. The Tax Agency disagreed, contending that VAT liability only arises when services are performed. On appeal, the City Court found that: 1) the taxpayers didn’t prove that the VAT liability and the right to deduct arose at the time of the advance invoicing; ...

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