Tax cases · 12 June 2026
Full victory in a tax case, alleged wage income reduced to DKK 0
The matter was conducted by attorney Hussain Ali Alhaidary. Hussain Ali Alhaidary
We obtained full relief in a tax case where the Danish Tax Agency had increased a client's income on the basis of time sheets from a third party. The income was reduced to DKK 0.
Can a person be taxed on wages merely because their name appears on a time sheet held by a company?
That question was central to a tax case in which we assisted a client whose income the Danish Tax Agency had increased on the basis of information from a third party.
The case arose during the Tax Agency's audit of a company's withholding of A-tax and labour-market contributions. During the audit, the Tax Agency received a number of time sheets showing our client's name, address and CPR number together with a number of registered working hours.
On that basis, the Tax Agency assumed that the client had worked for the company. His taxable income was therefore increased by an amount calculated from the registered hours and an estimated hourly rate.
The Tax Agency had not documented that the work was performed
We argued that the Tax Agency had not discharged the burden of proving that our client had actually performed the work covered by the time sheets.
No other objective documentation linked the client to the work. In our view, the fact that his name and personal details appeared on certain lists did not in itself document that he had performed the work or received the alleged wages.
It was therefore our position that there was no basis for increasing his income.
The Tax Appeals Board found for the client
The Tax Appeals Board agreed with our claim.
The wage income that the Tax Agency had attributed to the client was therefore reduced to DKK 0.
The decision is a good example of how the decisive dispute in a tax case is not always about the interpretation of tax legislation.
Often the case is instead about something more fundamental: what actually happened, and what can the Tax Agency document?
Facts can be decisive in a tax case
In many tax cases it becomes decisive to test the factual basis of the Tax Agency's decision.
This applies, among other things, to cases where the Tax Agency builds a reassessment on information from an employer, a third party, bank records, time sheets or other documents.
The fact that a citizen's name appears on a document is not necessarily the same as the document proving the transaction or income that the Tax Agency wishes to tax.
A thorough review of both the documentation and the factual circumstances of the case is therefore often at least as important as the legal assessment.
Has the Tax Agency increased your income?
We assist in tax cases where the Tax Agency has increased a citizen's income on the basis of information from employers, third parties, bank accounts or other external sources.
If you have received a proposed or final decision from the Tax Agency that you believe rests on an incorrect or insufficient factual basis, you are welcome to contact us for a non-binding assessment of your case.
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