78 | Annual Report 2018 Ministry of Taxation The following statements on cases concluded in 2018 have been published: 2018-10. Own-initiative investigation of 30 cases processed by Customs and Tax Administration and National Tax Tribunal In a general investigation opened on the Ombudsman’s own initiative, the Ombudsman reviewed 30 cases, each of which had been processed by both the Danish Customs and Tax Administration (SKAT) and the National Tax Tribunal. The investigation was carried out under section 17(2) of the Ombudsman Act, which authorises general investigations by the Ombudsman of an authority’s processing of cases. The Ombudsman’s investigation comprised the processing of the cases by both SKAT and the National Tax Tribunal, including the secretariat services provided by the Tax Appeals Agency. The investigation focused on the authorities’ observance of rules and principles of administrative law, especially in relation to matters which may be said to have significance for furthering good, trusting relations between the tax authorities on the one hand and citizens and businesses on the other. In the Ombudsman’s opinion there were several in­ stances of errors etc. which might be liable to affect relations between tax authorities and taxpayers. These errors concerned specific forms of conduct, inadequate registration of documents by SKAT, tax assessments based on estimates which did not appear to be founded on objective criteria, inadequate answers to arguments and views put forward by taxpayers and failure to establish whether time limits for tax assessment had been observed. The Ombudsman sent a draft report to the tax authorities, asking them for their comments. In this connection, SKAT gave an account of a number of measures which had already been initiated or which would be initiated on the basis of the ombudsman’s report. The Ombudsman stated that, as far as he could judge, the measures pointed out by the tax authorities appeared very relevant. He added that it was important that the measures were implemented effectively and in a focused manner, and he asked SKAT to inform him about the measures which it would initiate in future as a consequence of his report. 2018-16. Inadequate registration of claims for refunds of dividend tax and inadequate guidance on website A man complained to the Ombudsman because he had not received any replies to a number of letters which he had sent to the Danish Customs and Tax Administration (SKAT) five years earlier, claiming refunds of dividend tax. The case caused the Ombudsman to open a general investigation on his own initiative of SKAT’s handling of older cases concerning claims for refunds of dividend tax. SKAT informed the Ombudsman that for a number of years until 2016, it had not had an overview of the progression of cases concerning claims for refunds of dividend tax and only a limited number of such cases had been registered correctly. SKAT found this severely regrettable, and the Ombudsman agreed. In addition, the Ombudsman was of the opinion that when it emerged that there were claims for refunds of dividend tax which had not been registered, SKAT should have taken such steps as it could in order to locate claims which had not been registered. On its website, SKAT provided general guidance on the processing of cases concerning claims for refunds of dividend tax, but SKAT did not mention the possibility that claims might have gone astray. Therefore, the Ombudsman found that SKAT’s guidance on its website could not be regarded as adequate. As SKAT could not exclude the possibility that there were still claims which had not been located, the Ombudsman recommended that SKAT consider updating its website with guidance in this respect.