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The new rules mean that VAT deductions can be made for up to 6 months after the supplier's invoice date in the VAT return that is currently to be submitted. This means that VAT deductions are obtained without the VAT deduction having to be reversed to the VAT return where the supplier's invoice is dated.

Please note that the input VAT deduction must be made according to the same principles for all supplier invoices. If, for example, the principle is that the VAT deduction is taken after the purchase has been finally approved, then this principle must be applied to all VAT deductions/input VAT vouchers.

It is therefore recommended that a short internal note is made stating which principle is used for VAT deductions and that the system setup follows this principle. The consequence of deviations is, as is well known, a risk of interest charges from the Danish Tax Agency.

The amendment to the VAT Executive Order may not resolve the need for accrual of deductions for energy taxes, and there may also be an issue regarding the accrual of VAT deductions for purchases from outside Denmark (reverse charge). This will be followed up with a view to clarification.

"Subsection 3. Input tax may be recorded by recording the expense in the business accounts instead of upon delivery. As a rule, entry must be made in the tax period immediately following the tax period in which the deductible purchases are delivered. Entry may, however, be made in later tax periods, but no later than 6 months after the time when the deductible purchase is delivered. The input tax is then calculated on the basis of the entries made in the business accounts during the tax period.

Subsection 4. Input tax shall be recorded according to the same method in this provision for all purchases in the individual tax period; however, input tax may only be recorded once."

If you need advice or guidance as to how this new VAT executive order apply to you � feel free to reach out to us.