inwema

Expertise

Moving to or from Denmark

For anyone moving to or from Denmark who needs to know when Danish tax liability starts or ends. We cover the factors Skattestyrelsen (the Danish Tax Agency) looks at, and the decisions to make before the moving date is fixed.

Your home, time spent in each country, work and family all affect when Danish tax liability starts or ends.

We plan the sequence of housing, employment and relocation. We also review exit tax, payment deferral and returns for the year of the move.

How we can help

  • Start and end of tax liability
  • Planning before fixing the moving date
  • Exit tax and deferral
  • Treaty residence
  • Tax returns for the year of arrival or departure

When do you become fully tax liable in Denmark?

Full tax liability starts when you both have a home available in Denmark and take up residence here. If you have no home here, you become liable after a continuous stay of at least 6 months, and short holidays abroad do not interrupt that period.

If you have a home in Denmark but live in another country, short stays for holidays or similar purposes do not trigger tax liability. In practice, the limit is a continuous stay of no more than 3 months and no more than 180 days in any 12-month period. Working during the stay points the other way, and only occasional work of up to 10 days in 12 months is accepted.

When does tax liability end when you leave Denmark?

The key question is whether you give up your residence in Denmark. If you keep access to a year-round home, tax liability generally continues unless you can show that you have settled permanently abroad. Objective steps such as selling or letting the home carry more weight than stated intentions.

If you want to keep the home, you can let it on a lease that cannot be terminated for at least 3 years, so that it is not available to you during that period. A summer house used only for holidays is normally not a residence. If your spouse stays in Denmark, that points strongly towards your tax liability continuing.

What is exit tax on shares, and can you defer it?

If you own shares with a combined market value of DKK 100,000 or more when your tax liability ends, they are generally taxed as if they had been sold. The rule applies if you have been liable to Danish tax on share gains for a total of at least 7 of the last 10 years.

You can defer the tax by filing form 04.065 with a statement of your holdings. The deadline is 1 July in the year after you leave, and the form must be filed every year after that. If you move outside the EU and the Nordic countries, security must be provided, and dividends and sales trigger repayments on the deferred amount.

Which country are you resident in under a tax treaty?

You can be fully tax liable in two countries at the same time. The double tax treaty then decides which country is your tax residence. The test follows a fixed order: permanent home, centre of vital interests, habitual abode and nationality.

When you move to Denmark, shares you already own are generally treated as acquired at their market value on the date you arrive. Document that value while it is still easy to obtain. In the year of the move, income must be split between the periods before and after, so that the two countries' tax returns match.

Frequently asked questions

When does my Danish tax liability end if I move abroad?

It ends when you no longer have a residence in Denmark. If you keep access to a year-round home, it generally continues. Selling the home or letting it on a non-terminable lease for at least 3 years are the usual ways to give up your residence.

How much time can I spend in Denmark after moving away?

If you have kept a home in Denmark, stays of up to 3 months in a row and 180 days in any 12-month period are accepted as holidays or similar. Working in Denmark during those stays can trigger tax liability, and only occasional work of up to 10 days in 12 months is accepted. If you have no home here, you become liable after a continuous stay of 6 months.

Do I pay tax on my shares when I leave Denmark?

You may, if your shares are worth DKK 100,000 or more in total and you have been liable to Danish tax on share gains for at least 7 of the last 10 years. The gain is calculated as if the shares had been sold when you left. You can defer payment, but you must file form 04.065 by 1 July in the year after you move.

What happens if I am tax resident in two countries at once?

A double tax treaty then decides which country you are resident in. That country has the primary right to tax, while the other can usually only tax specific income, such as salary for work performed there. Where no treaty exists, you can instead claim relief under Danish domestic rules.

How are shares I own taxed when I move to Denmark?

Shares that were not already subject to Danish tax are generally treated as acquired at their market value on the date your tax liability starts. This means only the increase in value after you arrive is taxed here. Keep documentation of the value on that date.

What does this mean for you?

This page is general. Your own situation may be different, so talk to us before you act on it.