The Danish Tax Administration has updated its rules for correcting wrongly invoiced VAT: suppliers no longer need to prove they will return the VAT to customers, and any refund disputes are now considered private legal matters. However, some conditions still apply, such as the need for a credit note or invoice correction, and in certain cases, buyers may claim VAT refunds directly from the tax authority. Special cases, like mistakenly registered employees, will be reviewed individually.
Denmark Updated VAT Refund Rules for Incorrect Invoicing
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Denmark
Author: Ivana Picajkić
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General information
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344
Content accuracy validation date:
25.07.2025
Content accuracy validation time:
12:38h
The Danish Tax Administration has changed its approach to correcting incorrectly invoiced VAT. Suppliers no longer need to prove they will pass on the refunded VAT to the customer. Any disagreement between the two parties about the refund is now considered a private legal matter, not a tax issue.
Main elements of the New Guidance:
No more mandatory refund commitment:
- Suppliers can request a VAT refund without showing they’ll give the money back to the customer,
- Disputes about the refund are handled between the supplier and customer, not the tax authority.
Certain limits still apply:
- No credit note or replacement invoice?
- If a credit note or corrected invoice can’t be issued, the old rules still apply,
- In such cases, the supplier may still need to commit to passing on the refund.
- Buyer can’t claim from supplier?
- If it’s too difficult or impossible for the customer to claim from the supplier, and VAT has already been paid, the buyer may claim directly from the Danish Tax Agency.
- Supplier uses limitation period defense?
- If the supplier says it’s too late for the customer to make a claim but still requests a refund, the Tax Agency will reject the refund.
- Refund already paid to supplier?
- If the supplier already received the VAT refund, the customer cannot claim it again from the Tax Agency.
- Employees mistakenly registered as taxable persons
- These cases will be reviewed individually, invoice by invoice and client by client.
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