54 | Annual Report 2019 regarded as a decision. The Ombudsman therefore stated that it was important that the customer centre was more mindful in future of ensuring that it was conveyed clearly that the centre’s replies are intended as a guide only. Further, the Ombudsman was of the opinion that in a few cases the customer centre had not answered the questions adequately or provided sufficient guidance on what the next step was. In addition, the Ombudsman found some examples of answers which were unclear or misleading because they did not contain sufficient background information or references to where further information on the applicable law could be found. Finally, the Ombudsman found examples of answers which were not clear and easy to understand, typically because specialist terms or jargon had been used without being explained. 2019-33. Non-compliance by Danish Customs and Tax Administration with Act on Due Process in Connection with the Public Administration’s Use of Compulsory Intervention and Duties of Disclosure in connection with requests for information and assessment of suspicion in linked specific cases (Panama Papers) In 2018, the Parliamentary Ombudsman concluded a general investigation of whether the Danish Customs and Tax Administration (SKAT) had complied with the rules in section 10 of the Act on Due Process in Connection with the Public Administration’s Use of Compulsory Intervention and Duties of Disclosure on the privilege against self-incrimination in connection with 176 requests for material which information from the so-called Panama Papers had caused SKAT to send to citizens. In these requests, SKAT ordered the citizens to send in information so that it could be established whether they owed tax to Denmark. Following this general investigation, the Ombudsman carried out an investigation of SKAT’s requests for information and its assessment of suspicion in a number of linked specific cases about which he had received information from a practising lawyer. The lawyer represented a citizen who had received one of the 176 requests for material sent by SKAT. It was the lawyer’s understanding that SKAT had had a specific suspicion at an early stage of its processing of the linked cases that his client had committed a criminal offence, and he added that his client should therefore have been informed about his rights under section 10 of the Act on Due Process in Connection with the Public Administration’s Use of Compulsory Intervention and Duties of Disclosure at an earlier date than he was. The citizen had received several requests for material and reminders from SKAT – at first on the basis of information received by SKAT by virtue of a directive on taxation of savings income in the form of interest payments and later also on the basis of information from the Panama Papers. Based on an overall assessment of the information in the linked cases, the Ombudsman concluded that SKAT had had grounds at an earlier point than considered by the tax authorities for a specific suspicion that the citizen had committed a criminal offence. The Ombudsman therefore found it regrettable that SKAT had not complied with the rules in section 10 of the Act on Due Process in Connection with the Public Administration’s Use of Compulsory Intervention and Duties of Disclosure when requesting information from the citizen. The Ombudsman stated that it could not be inferred from his conclusions in relation to the linked cases that errors had also been committed in the other cases which had been opened on the basis of information from the Panama Papers. However, he added that he assumed that – in the light of what he had stated – the Danish Tax Agency (formerly SKAT) would consider whether there were grounds for a detailed review of one or more of the other cases which had been