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DenmarkRetsinformation

Collection bill ends refund assignments, pairs plate seizure with recovery

L 38, tabled 7 October 2026, puts wrong-levy interest on a statutory footing, bans pledging tax refunds and lets recovery run alongside plate seizures from 1 January 2027.

By Taxxa AI OyPublished 8 October 2026

Tax Legal & Corporate

Vehicle dealers, leasing companies and any business or taxpayer with claims against or debts to the Danish tax administration face new collection rules under bill L 38Retsinformation, tabled in the Folketing on 7 October 2026Retsinformation by the Minister for Taxation and Growth. The bill implements parts of the June 2023 agreement on effective collection and debt recovery. Most of the act would enter into force on 1 January 2027Retsinformation, with a handful of provisions taking effect on dates the minister sets.

From 1 January 2027 no claim against the customs and tax administration could be assigned to a third party or made subject to execution, except in the creditor's bankruptcy, reconstruction or insolvent estateRetsinformation. Cost-reimbursement claims under section 52 of the Tax Administration Act stay transferable. Transfers through merger, business transfers or dissolution of a legal person including liquidation remain possible, but only after the claim has arisen and only up to the payout amount computable under section 12(5) of the Collection Act. Assignments notified before 1 January 2027 stay under the current rulesRetsinformation.

Interest on refunds of wrongly levied tax would move from the Legal Guide into statuteRetsinformation. A new section 61 a of the Tax Administration Act provides that repayment claims for taxes, duties, fees and interest levied without authority bear interest from the payment date through the refund dateRetsinformation on the administration's own initiativeRetsinformation. The rate starts as section 5 of the Interest Act (10 per cent per annum in the second half of 2026)Retsinformation and switches to section 7 of the Collection Act (11.4 per cent in 2026) once systems are adaptedRetsinformation. Municipal pass-through duties, contractual claims, fines and overpayments caused by the payer's own error are excludedRetsinformation, and interest below DKK 50 for the period is not paidRetsinformation.

Overpayments caused by the payer's own mistake bear interest only from 30 days after the administration receives the refund request or itself establishes the errorRetsinformation. The same periods are mirrored for the debt-recovery authority in section 8 c of the Debt Collection Act, where the rate stays the section 8 c rate.

For periodic motor duties the administration could hand a claim to the debt-recovery authority once the deadline has passed and the usual reminder procedure has failedRetsinformation, even while a number-plate seizure request is still with the policeRetsinformation. Today seizure must play out first, stretching collection to 12-14 months; the bill expects around three. Interest is excluded from the seizure basis and the principal duty itself must be at least DKK 100Retsinformation.

Quarterly registration-duty permits are tightened: the first levy adds a regulating amount from the first of the quarter to the decision date, the permit takes effect only on paymentRetsinformation, and shortfalls end the permitRetsinformation. A deposit covering arrears is reused immediately against a missed advance payment, with a fresh deposit collected before the next quarter, and plates not deregistered when a permit ends trigger full registration dutyRetsinformation. Underpayments from wrong registration data and several leasing-duty adjustments get a 21-day deadline from the demand letterRetsinformation, extended past bank holidays. Businesses whose security has been fully consumed covering arrears within 12 months must top it upRetsinformation, joint liability for reminder fees ends except where the business form imposes itRetsinformation, and other payouts gain a three-week deadlineRetsinformation with Collection Act interest on late payment.

Legal basis: bill L 38 (Fremsat den 7. oktober 2026) amending the Collection Act (opkrævningsloven), the Registration Duty Act (registreringsafgiftsloven), the Tax Administration Act (skatteforvaltningsloven), the Debt Collection Act and others.

Stop pledging tax-administration payouts as loan collateral from 1 January 2027; align motor-duty recovery and registration-duty permit routines with the new deadlines.

Sources