In a change to the current Danish VAT practice, the Danish Tax Authorities (SKAT) (in its recent draft guidance) have supported the decision from the EU Court of Justice of Larentia + Minerva (on 16 July 2015) and confirmed that for Danish VAT purposes holding companies are entitled to fully (100%) deduct VAT incurred on costs relating to the purchase of share interests.
This means that active holding companies who have not fully recovered the VAT incurred on costs may be entitled to a refund of VAT (including interest) from SKAT for the past 10 years (i.e. from 1 April / 1 June 2005 onwards).
The deadline for submission of the refund claims is six months after the publication of the final guidance (i.e. expected spring / summer 2016).