Holding company acquitted in transfer pricing penalty case: The judge agreed with all of our arguments

The Court in Viborg acquitted my client, Genan Holding A/S, on 12 March 2026 of a penalty claim concerning the late submission of transfer pricing documentation.
The company had chosen to pursue the case at its own expense because it considered the matter to be clearly unreasonable – and because I assessed that there was a strong case supported by substantial legal arguments.
Case concerning possible VAT violation due to lack of registration in the One-Stop-Shop was dismissed.

Bachmann/Partners recently assisted an international company in a criminal case brought by the Danish Tax Agency. The case concerned the company’s previous handling of VAT in connection with distance sales to Denmark in the period 2019–2021.
Before our involvement, the Danish Tax Agency had assessed that the company should be fined DKK 590,000, as they believed the company had acted with gross negligence in relation to the missing Danish VAT registration.