The Amsterdam Court of Appeal has cleared the way for Danish tax authorities to pursue a claim of about 95 million kroner against Dutch financier Frank Vogel. The ruling overturns a 2024 decision that had frozen the case in the Netherlands.
DR reports that the Danish tax authorities have won an important procedural round against Vogel, whom they accuse of being the mastermind behind dividend tax fraud. The appeal court decision was published at the end of July 2026.
Danish authorities allege that Vogel played a central role when three small Canadian pension funds obtained roughly 95 million kroner in Danish dividend tax refunds between 2013 and 2015. According to DR, the authorities argue the funds never owned the Danish shares and never paid tax on them. Denmark is seeking to recover every krone.
Since 2024, a Dutch court had blocked the claim against Vogel and several of his companies. The court in Noord-Holland chose to pause proceedings while awaiting rulings in both Denmark and Canada. That decision, registered as ECLI:NL:RBNHO:2024:7511, was also described by the Dutch tax outlet Taxlive.
Why the case is moving now
The main reason for the reversal is a final Danish ruling. Per DR, the appeal court points to Landsskatteretten, the Danish National Tax Tribunal, which decided on May 13, 2025 that the Canadian pension funds had not proved ownership of the shares behind the refunds. In other words, the funds were not entitled to the money.
A decision is still pending in Canada, where Danish authorities have sued the three pension funds. According to the published judgment, Danish authorities expect that ruling to take several more years. The Dutch court found no reason to wait, since Vogel and his companies could still be held liable regardless of the Canadian outcome.
DR asked Vogel for comment on the ruling. His lawyer said he does not wish to comment. The same lawyer previously told DR that the Danish claim is a false accusation that his client rejects. Skattestyrelsen had not responded to DR’s questions about the timing of the main case.
The case against Vogel dates back to a 2020 lawsuit filed by Danish authorities against the three Canadian pension funds. Dutch court documents from July 2024 state that Danish authorities accuse Vogel of acting unlawfully by being directly involved in the funds’ alleged fraud. Documents and digital files were seized in May 2023 and remain held as evidence.
The Dutch proceedings are purely civil. Vogel is also under criminal investigation for dividend tax fraud in the Netherlands and Germany, where he risks prison if convicted. He denies wrongdoing.
Cases are currently pending against around 185 people and companies across the United States, England, the Netherlands, Dubai, Malaysia, Canada, and Denmark. That figure comes from a June 2026 budget document from Tax Minister Jakob Engel-Schmidt of the Moderates. So far, 4.2 billion kroner has been returned to the Danish treasury, with total recovery expected between 8.8 and 9.2 billion kroner. Costs, mainly legal fees, are estimated at 4.3 billion kroner.
