Cross-border inheritance and gifts

When is Danish estate duty payable?

What matters is where the deceased was domiciled at the time of death, not where the heirs live. If the deceased was domiciled in Denmark, Danish boafgift (estate duty) generally covers the entire estate, including property and bank accounts abroad.

If the deceased was not domiciled in Denmark, the duty only covers real property in Denmark and assets linked to a permanent establishment here. A Dane living abroad with a summer house in Denmark can therefore trigger Danish estate duty on the summer house, even if the rest of the estate is administered abroad.

In 2026, the estate pays 15% estate duty on inheritance to close family above a threshold of DKK 392,300. Other heirs also pay a 25% tillægsboafgift (additional estate duty) on what remains. Spouses and registered partners pay no estate duty.

How do you avoid paying duty on the same inheritance in two countries?

Denmark has only a few agreements on double taxation of inheritance and gifts. The most important is the joint Nordic agreement between Denmark, Finland, Iceland, Norway and Sweden. Ordinary double tax treaties usually cover income tax only, not inheritance and gifts.

Where there is no agreement, boafgiftsloven (the Danish Estate Duty Act) allows estate or inheritance tax paid abroad on assets located there to be deducted from the Danish estate duty. The deduction cannot exceed the Danish duty on the same assets. If the foreign duty is higher, the difference is not compensated.

The deduction requires documentation of both the foreign duty and the value of each asset. Foreign property must be included at market value in the Danish calculation, and the value used abroad is not necessarily the one Denmark accepts.

When is a gift from abroad subject to Danish gift tax?

Danish gaveafgift (gift tax) applies if either the giver or the recipient is domiciled in Denmark. If you both live abroad, Danish gift tax only applies if the gift consists of real property in Denmark or assets linked to a permanent establishment here.

In 2026, close family can receive DKK 80,600 free of gift tax, and sons- and daughters-in-law DKK 28,200. Above the threshold, the tax is 15%, while gifts to grandparents and step-parents are taxed at 36.25% in total.

The gift tax return must be filed no later than 1 May of the year after the gift. A waived loan or a property transferred below market value can also be a gift, including when the money crosses a border.

Why can two countries see the same estate differently?

As a starting point, an inheritance is distributed under the rules of the country where the deceased lived at the time of death. Denmark does not take part in the EU Succession Regulation, while most other EU countries do. Two countries may therefore disagree on which country's inheritance rules apply and who should administer the estate.

• A will is drafted under one country's rules but has to be used in a country with forced heirship or other formal requirements.
• Property abroad is missing from the Danish estate accounts or is valued on the basis of a foreign assessment.
• A gift from a parent abroad is not reported, because the giver does not live in Denmark.
• Foreign duty is paid without securing the documentation needed for the Danish deduction.