
Financial Review (continued)
Uncertainties of recognition and measurement
At each reporting date, it is required to assess whether there is
any indication that an asset may be impaired. The current
uncertainties in the market and the share price from the last
capital increase, among others, indicate that an impairment
assessment needs to be performed, with main focus on the
carrying amount of the intangible assets.
Development projects have a net value of DKK 67.6M (2023: DKK
75.0 million) in the annual report. Development projects are
measured at cost price reduced with amortization and
write-downs. The measurement of development projects is
dependable on future earnings, which there is a natural
uncertainty related to. Growth in 2024 and outlook corresponds
to a lower growth than mid-term financial targets. If future
growth continues to be lower than mid-term financial targets
this could entail an impairment loss of the value of capitalized
Development projects. Due to these circumstances, there is
material uncertainty related to the value of capitalised
development projects.
Going concern
Linkfire A/S’s continued operations depend on refinancing
(capital injection from investors or new loans) of interest-bearing
liabilities in the range of DKK 40 million. Furthermore,
postponement of repayment of the current portion of the
interest-bearing liabilities in the range of DKK 18 million is
required for the company to continue operations. Management
expects that both the refinancing and postponement of
repayments due in 2025 in the range of DKK 18 million will be
concluded before the end of September 2025. The refinancing
may be conducted in one or more steps, and the company’s
management has constructive dialogues regarding potential
capital injections and dialogues with both current and potential
new debt providers, Management has, on this background,
decided to prepare the financial statements on a going concern
basis.
However, due to uncertainty related to both refinancing and
terms and conditions related to postponement, there is material
uncertainty related to going concern.
Tax Credit Scheme
Last year, the Danish Tax Authorities requested Linkfire to share
its calculations for received payouts under the Tax Credit
Scheme for FY 2020 and 2021. Under this program, the Tax
Authorities encourage innovation in Denmark, supporting Danish
loss-making, innovative companies with paying out the tax value
of qualified research and development costs. The program is a
great driver for keeping innovation in Denmark and for global
exposure to Denmark as an accommodating and innovative
business market. This is a regular procedure conducted by the
Tax Authorities. The event prompted management to reiterate
the implicit uncertainty in receiving payouts under the Tax Credit
Scheme since calculations and assumptions can be challenged.
Linkfire received DKK 4.5 million in 2021 (for FY 2020) and DKK
5.5 million in 2022 (for FY 2021), and expected to receive DKK 5.5
million in November 2023 (for FY 2022) and DKK 5.2 million in
November 2024 (for FY 2023)..
Linkfire’s management believes in having solid documentation
for its innovative development in the global audio entertainment
market and welcomes the control as an important part of such a
supportive arrangement for innovation in Denmark. Linkfire
delivered its first batch of documentation to the Tax Authorities,
who had an initial proposal to change Linkfire’s taxable income,
and needed to see further documentation. Therefore, the Tax
Authorities were invited to Linkfire’s office for a walkthrough of
our product and developments during the challenged years,
and asked Linkfire to prepare additional documentation to prove
the innovative element of the developments, which was
delivered in March 2024.
In April 2024, Linkfire received the decision by The Danish Tax
Authorities, who deemed Linkfire ineligible, demanding
repayment of DKK 12.3M including interest as of April 2024 for
FY 2020 and 2021, and rejecting payment of the expected funds
corresponding to FY 2022, which was recognized as tax
receivable of DKK 5.5 million. In addition, in April 2025 Linkfire
received the decision by The Danish Tax Authorities rejecting
payment of the expected funds corresponding to FY 2023.
Many Danish software companies are facing the same decision
from The Danish Tax Authorities regarding R&D under the Tax
Credit Scheme. Based on the advice from tax specialists, Linkfire
appealed the decision to the Danish Tax Tribunal, including a
deferred payment request, meaning no payments need to be
made until the Tax Tribunal makes a final ruling .
Throughout the second half of 2024 and into early 2025, Linkfire
has supported the preparation of a technical expert review to
substantiate the innovative nature of its R&D activities in the
relevant fiscal years. This included providing supplementary
documentation, clarifying technical product advancements, and
referencing benchmarks of comparable innovation cases across
the Danish software sector.
While the Danish Tax Tribunal has not yet appointed an expert or
confirmed the precise process, it is expected that the case will
progress in the second half of 2025, beginning with the expert’s
assessment as a preliminary step ahead of district court
evaluation.
As a result of the uncertainty associated with the outcome of the
final decision, in FY 2024, no tax receivable has been recognised
and accrued interest has been provisioned for the year. As per 31
December 2024, the total provisioned liability amounts to DKK
13.3M.
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