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
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