Tax cases · 11 April 2026
Full success on appeal, taxable income reduced by DKK 605,000
The matter was conducted by attorney Hussain Ali Alhaidary. Hussain Ali Alhaidary
We represented a client in an appeal where the Danish Tax Agency had taxed a number of transfers from friends and family as taxable income. The taxable income was reduced by more than DKK 605,000.
We represented a client in an appeal, where the Danish Tax Agency had taxed a number of money transfers from friends and family as taxable amounts.
After the case was heard before the Tax Appeals Agency and the National Tax Tribunal, the client's taxable income was reduced by more than DKK 605,000, corresponding to approximately 63 % of the original increase.
The decisive question was whether the amounts received were taxable gifts or whether they were genuine loans.
The transfers were loans, not taxable gifts
The Danish Tax Agency had assumed that the money transfers the client had received from friends and family should be taxed.
We argued that the transfers were tax-free loans and not gifts or other taxable income.
The case therefore placed emphasis on documenting the loan relationships and the factual circumstances surrounding the transfers, including the relationship between the parties, the flow of funds and the obligation to repay.
We succeeded in establishing that a substantial part of the amounts were, in reality, loans.
The income was reduced by 63 %
The result was that the client's taxable income was reduced by more than DKK 605,000.
This corresponds to a reduction of approximately 63 % compared with the Tax Agency's decision.
The case shows how much significance the overall documentation can have in tax cases concerning private loans, transfers between friends and family, and amounts that the Tax Agency considers taxable.
Private loans require documentation
When the Tax Agency questions private money transfers, it is rarely enough simply to explain that the transfer is a loan.
It may be necessary to document, among other things:
| Matter | What should be documented |
|---|---|
| Transfer | How and when the amounts were transferred |
| Lender | Who provided the loan |
| Repayment | Whether there is a genuine obligation to repay |
| Flow of funds | Whether the flow of funds can be traced |
| Other circumstances | Whether the other circumstances support that it is a loan |
Has the Tax Agency taxed transfers from friends or family?
We assist on an ongoing basis in tax cases concerning private loans, gifts, bank deposits and transfers between family members and other private parties.
If you have received a proposed decision or a decision from the Tax Agency where private transfers have been treated as taxable income, you are welcome to contact us for a non-binding assessment of the case.
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