Denmark – Update on new fund tax regime

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Denmark – Update on new fund tax regime

14 January 2020

Operational Tax News

The Danish Tax Authorities (DTA) have published the list of funds that have applied for the newly introduced fund tax regime and are considered as equity-based investment companies as from 2020.

The Liste over aktiebaserede investeringsselskaber 2020 can be retrieved via the following link: https://skat.dk/skat.aspx?oid=2244641
 

The New Danish Fund Tax Regime – a short reminder

A new regime, applicable as from 2020, has been introduced in order to make foreign funds more attractive for individual Danish investors. Under the new regime, yield on “equity-based investment companies” is taxed as “share income” instead of “capital income”, resulting in lower tax rates applicable within certain brackets.

Foreign funds that fulfil the conditions to be considered as equity-based investment companies according to Danish tax rules can elect to enter the new regime.

An initial notification to the Danish Tax Authorities must be made no later than 1 November prior to the calendar year for which the election should have effect. Initial notifications for the year 2021 should be filed before 1 November 2020.

On a regular basis, the fund must submit asset test information to the Danish Tax Authorities for assessment of whether the fund fulfils the requirements to be considered as equity–based no later than 1 July of the year following the calendar year for which the regime should apply. Asset test information for the year 2020 should be submitted before 1 July 2021.

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Deloitte Luxembourg

Jacquou Martin
Managing Director
Pan-European Tax Services
jacmartin@deloitte.lu
T +352 45145 2174

Deloitte Denmark

Dorte Vestergaard Sonnichsen
Director
Tax and Legal
dsonnichsen@deloitte.dk
T +45 30 53 05 64

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