Skip to main content

Denmark: Business conversion between related parties may be reclassified from tax-free to taxable within extended six-year period (Supreme Court decision)

Application of extended six-year period under section 26(5) of the Tax Administration Act

Share
february 10, 2026

The Supreme Court on December 16, 2025, held that the tax authority may reclassify a business conversion between related parties from tax-free to taxable after the ordinary four-year deadline, provided the change is made within the extended six-year period under section 26(5) of the Tax Administration Act.

For more information, contact a KPMG tax professional in Denmark:

Lars Terkilsen | lars.terkilsen@kpmg.com

Thank you!

Thank you for contacting KPMG. We will respond to you as soon as possible.

Contact KPMG

Use this form to submit general inquiries to KPMG. We will respond to you as soon as possible.
All fields with an asterisk (*) are required.

Job seekers

Visit our careers section or search our jobs database.

Submit RFP

Use the RFP submission form to detail the services KPMG can help assist you with.

Office locations

International hotline

You can confidentially report concerns to the KPMG International hotline

Press contacts

Do you need to speak with our Press Office? Here's how to get in touch.

Headline