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Global Mobility Services, Taxation of International Assignees Country – Denmark

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Global Mobility Services, Taxation of International Assignees Country – Denmark www.https://www.pwc.dk/ Global Mobility Services, Taxation of International Assignees Country – Denmark People and Organisation Global Mobility Country Guide (Folio) Last Updated: January 2017 This document was not intended or written to be used, and it cannot be used, for the purpose Menu of avoiding tax penalties that may be imposed on the taxpayer. Country: Denmark Introduction: International assignees working in Denmark 4 Step 1: Understanding basic principles 5 Step 2: Understanding the Denmark tax system 9 Step 3: What to do before you arrive in Denmark 18 Step 4: What to do when you arrive in Denmark 23 Step 5: What to do at the end of the year 25 Step 6: What to do when you leave Denmark 26 Step 7: Other matters requiring consideration 28 Step 8: Special tax regime for expatriates 31 Appendix A: Tax rates 2017 33 Appendix B: Income tax calculation for 2017 34 (single taxpayer) Appendix C: Income tax calculation for 2017 35 (married couple) Appendix D: Income tax calculation for 2017 36 (single taxpayer/expatriate scheme) Appendix E: Double-taxation agreements 37 Appendix F: Denmark contacts and offices 38 Additional Country Folios can be located at the following website: Global Mobility Country Guides Global Mobility Country Guide (Folio) 3 Introduction: International assignees working in Denmark This folio serves as an introduction to the Introduction International Co-operation principal provisions governing direct Denmark, Greenland and the Faroe Islands In language as well as in culture, taxation of individuals and is designed to constitute the Kingdom of Denmark. Denmark is closely related to the inform both the foreign employee and other Nordic countries and is his/her employer about the most common Denmark covers an area of 43,000 sq. km also a member of the Nordic issues relating to transfers to Denmark. It and consists of the peninsula of Jutland Council and the Nordic Council only reflects Danish legislation as of 1 and 406 islands of which the Islands of of Ministers. January 2016 as the Danish tax rules are Zealand and Funen are the biggest. The amended on a continual basis. population is slightly more than 5.6 million The purpose of Nordic of whom 25% live in the metropolitan area co-operation is to harmonise Only the tax rules, which apply to of the capital, Copenhagen. legislation in the member Denmark, including the continental shelf, countries (Iceland, Norway, are described. The taxation systems for Greenland covers an ice-free area of Sweden, Finland, and Denmark), Greenland and the Faroe Islands are not 410,450 sq. km and has a population of to lower customs tariffs and to covered. Nor are the special rules approximately 57,500. The principal city promote the free movement addressed, which apply to individuals is Nuuk with its 16,000 inhabitants. of labour. engaged in pilot studies, or the exploration The Faroe Islands cover an area of and extraction of hydrocarbon. Denmark has also been a member 1,399 sq. km and has a population of of the European Union (EC) since The various rules are described separately. approximately 48,500 inhabitants. 1973. The membership does not In some cases, only one rule applies, but in The principal city is Thorshavn with its include the Faeroe Islands and many cases a number of rules will apply. 19,900 inhabitants. Greenland. Denmark has opted A number of issues can be extremely The Political System out of the EU in the fields of important when planning an assignment to justice and home affairs, the Denmark is a constitutional monarchy Denmark. The Danish tax rates are high common security and defence and the present monarch is Queen and the tax system is very complex. The policy, the EMU and the Margrethe II. information given in this folio is not citizenship of the European intended to be comprehensive and before The Danish Parliament (Folketing) has one Union but has entered into any action is taken further information and chamber with 179 members including 2 separate agreements in more detailed advice should be sought by members from the Faroe Islands and 2 some areas. consulting us. Please find our office members from Greenland. Currency addresses and contact Both the Faroe Islands and Greenland persons in Appendix F. The Danish currency is krone have extensive home rule with local and øre. 1 krone is 100 øre. government and parliaments responsible For more information see for local legislation. www.nationalbanken.dk. 4 People and Organisation Step 1: Understanding basic principles The scope of taxation in 6-month period, short stays 8. Danish limited tax liability is Denmark outside Denmark due to relevant for: holidays, etc., are included, 1. An individual may be taxed whereas stays abroad due to – Salary for work in Denmark: employment may interrupt performed in Denmark the 6-month period. and paid by a foreign – As having full tax employer with no legal liability to Denmark; 5. Individuals who are resident venue in Denmark in Denmark are subject to full where the employee – As having limited tax liability to Denmark; or tax liability, i.e., liable to tax stay in Denmark for on their worldwide income, more than 183 days – According to special unless the individual is within 12 months; expatriate rules. considered to have the centre of his/her interests – Salary for work Full tax liability in another country, according performed in Denmark to a double residence clause and paid by an 2. A person becomes fully tax in a relevant double employer with a legal liable by taking up residence taxation treaty. venue in Denmark; in Denmark or staying in Denmark for more than 6. A person who is fully tax – Certain other types of 6 consecutive months. liable in Denmark will as a personal income main rule be taxed according including directors' 3. Residence in Denmark is to the ordinary tax scheme by fees, pension deemed to exist if an up to 51.95% (55.8% distributions and social individual acquires a home including AM-tax). A number security benefits; in Denmark and takes up of deductions are applicable residence there. Generally, – Remuneration covered and the effective tax rate is taxation commences from by the special rules on therefore lower in most cases. the date of arrival. hiring out personnel; Limited tax liability 4. An individual who does not – Income arising from a set up residence will become 7. A person not liable to full tax business enterprise subject to full Danish tax liability may become limited with a permanent liability from the first day of tax liable to Denmark. establishment his/her stay if he/she stays in Limited tax liability is in Denmark; Denmark for a period of at restricted to income from least 6 consecutive months. Danish sources. When determining the Global Mobility Country Guide (Folio) 5 – Income from property whole year. If the person is 12. A ruling from the Court of located in Denmark; limited tax liable to Denmark Justice of the European during part of the year, the Union (the "Schumacker – Dividends from Danish person can choose a ruling") states that a person companies; personal allowance. who has earned most of – Royalty income from his/her salary in the country Special expatriate rules in which he/she is considered Denmark; non-resident (limited tax 10. According to the special – Under certain expatriate tax regime, the tax liable to the country) should be allowed the same circumstances, rate on salary income is deductions on his/her taxable remuneration for reduced to a flat rate of 26% advisory activity. (31.92% including the labour income as a fully tax liable person in the same country. market tax) for 5 years. No 9. A person with limited tax Denmark has altered its deductions are allowed. liability to Denmark will as a internal regulations in main rule be taxed by up to 11. For hired out personnel the accordance with this ruling. 51.7% on income from taxation on salary income An individual with limited tax sources in Denmark. may be reduced to a flat rate liability to Denmark and who Deductions related to the of 30% (35.6% including the earns 75% of his/her global work performed are allowed. labour market tax). No income in Denmark can apply There is a personal allowance deductions are allowed. these rules. if the person is limited tax liable to Denmark during the 6 People and Organisation 13. A special employment The sum of taxable income from 2011 only double tax deduction of 8.75 of the is the same for individuals treaties apply. gross income applies for with either full or limited employees and self- tax liability. Municipal income 24.91% employed individuals. taxes (excluding church tax) on The deduction is limited 15. The different types of income are as follows: taxable income, at DKK 30.000 (2017). approximate rate (country average The rules are described in – Personal income: for 2017) further detail below. mainly salary and employment-related Health tax 2.0% Types of income benefits, self- Labour market tax 8.0% employment income 14. When assessing the tax and pension income; State taxes: under the ordinary tax Base tax on personal 10.8% scheme, the following – Capital income: income (+ positive types of income apply: mainly interest net capital income) income and expenses; – Taxable income; Top tax on personal 15.0% – Taxable income: the income (+ positive – Personal income; sum of the above net capital income) in adjusted for certain excess of DKK – Capital income; 479,600 (2017) itemized deductions; – Share income; – Share income: 16. In addition to the above, – Property income. dividends and capital municipalities impose a gains on shares; special church tax on Wealth tax has been members of the Danish State abolished as of 1 – Property income: Church (Lutheran).
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