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Generic Tax Name Corporate income tax - Fund income tax
Tax name in the national language Fondsbeskatning
Tax name in English Fund income tax
Member State DK-Denmark
Tax in force since 1988/01/01
If abolished, date on which the tax ceases to apply
Business version date 2013/01/01
Version date 2013/01/02
This file was last updated on

Type of tax
Direct taxes Personal income tax
Corporate income tax
Other

Indirect taxes VAT
Excise duty (EU harmonised)
Alcoholic beverages
Energy products and electricity
Manufactured tobacco
Other

Social security contribution Employers
Employees
Other
 
Legal base

Statutory Notice No 1248 of 2th November 2010

 
Who sets
The tax rate is set by




The tax base is set by




The reliefs are set by




Comments
 
Beneficiary





Comments

13.41% of the total revenue is distributed among the local authorities. (§13).

 
Geographical Scope
 
Taxpayers
Domestic-source income of non-resident entities is Taxed
Not Taxed
Comments

Funds covered by the law on foundations and certain associations or by the Law on commercial foundations, unless the foundation is exempted by these laws.

Associations covered by the law on foundations and certain associations.

Foundations and other independent institutions established abroad, on the Faeroe Islands or in Greenland when the place of management is situated in Denmark. That applies where-ever the foundation or the independent institution may be registered.

 
Tax object and basis of assessment
As general rule, taxable income under corporate income tax includes also








Comments

Income considered Domestic income
Worldwide income (subject to double-tax relief)
Comments

Comments

The funds and associations covered by the Fund Income Tax Law are to return their taxable income in the same way as companies covered by the Corporation Tax Law.

Non‑commercial income is taxed only if it exceeds DKK 25,000 or DKK 200,000 in the case of associations.

Funds and associations may deduct money that they distribute or allocate for purposes of public utility or other benevolent purposes. They may also deduct any money distributed pursuant to their statutes, provided the recipient is taxable on what he receives. Deduction reduced by tax free dividents recived.

The Fund Income Tax Law allows funds and associations to make a consolidation deduction in their income returns. Computed as 25 pct. of distributions for purposes of public utility or other benevolent purposes.

If a person, a company, a fund or association etc., contributes to a foreign fund or trust established in a country where the tax rates on funds or trusts are essentially lower than the Danish tax rate, the contributor is charged at 20% on the part of the annual contribution exceeding 10,000 DKK. Contributors may on request be exempted from the charge, if the amount of contribution to the foreign fund or trust is used for charitable or public purposes for the benefit of a wider circle of people.

 
Deductions, Allowances, Credits, Exemptions
Valuation of inventory
System First-in first-out (FIFO)
Last-in first-out (LIFO)
Average cost
Specific identification (unit method)

Comments

Depreciation rules
 
Buildings
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period 25  Years
Average depreciation rate
 
Movable (tangible) assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate 25.0 %
 
Movable fixed assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments

On movable fixed assets there is a choise between a depreciation rate of 7% and 19%. Please, see the corporate income tax for a description of this rule.

Average depreciation period
Average depreciation rate
 
Intangible assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate
 
Land (if any)
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate


Comments

The funds and associations covered by the Fund Income Tax Law are to return their taxable income in the same way as companies covered by the Corporation Tax Law.

Non‑commercial income is taxed only if it exceeds DKK 25,000 or DKK 200,000 in the case of associations.

Funds and associations may deduct money that they distribute or allocate for purposes of public utility or other benevolent purposes. They may also deduct any money distributed pursuant to their statutes, provided the recipient is taxable on what he receives. Deduction reduced by tax free dividents recived

The Fund Income Tax Law allows funds and associations to make a consolidation deduction in their income returns. Computed as 25 pct. of distributions for purposes of public utility or other benevolent purposes.

If a person, a company, a fund or association etc., contributes to a foreign fund or trust established in a country where the tax rates on funds or trusts are essentially lower than the Danish tax rate, the contributor is charged at 20% on the part of the annual contribution exceeding 10,000 DKK. Contributors may on request be exempted from the charge, if the amount of contribution to the foreign fund or trust is used for charitable or public purposes for the benefit of a wider circle of people.


Are there limits to interest deductions? Yes No
If yes:
Definition of deduction limit

Comments

Same rules as the corporate income tax.


Is there an Allowance for Corporate Equity? Yes No
If yes:
Notional rate applied for allowance

Comments

Losses
Loss carry-forward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 

Comments


Comments

Exemptions:

- Dividends received from subsidies.

- Non-commercial income is taxed only if it exceeds DKK 25,000 or in the case of associations DKK 200,000.

- Deductibility of distributions etc. as described above.

For a more detailed description of the rules on deduction, allowances, credits and exemptions please see the corporate income tax.

 
Rate(s) Structure
Nominal corporate income tax rate Rate: 25.00 %

Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate: 25.00 %


Comments

Special tax rate for SMEs
Special tax rates apply to SMEs: Yes No
If yes:
Nominal corporate income tax rate Rate:
Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate:


Comments
 
International aspects
Treaty countries Non-treaty countries
 
Repatriated profits are taxed according to the following system Exemption system Exemption system
Tax credit Tax credit
Deduction Deduction
 
Interest received is taxed Yes No Yes No
Tax rate on interest received 25.00 % 25.00 %
Outgoing dividends withholding tax
Outgoing interest payments withholding tax
 
Foreign losses can be set-off Yes No Yes No
If yes:
Minimum direct or indirect shareholding to qualify loss-offset (if applicable)
 
Loss carry-forward exists? Yes No Yes No
If yes:
Time limit: Indefinite
999  Years  
Indefinite
999  Years  
Size limit:
 
Loss carry-backward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Controlled foreign company (CFC-)rules exist? Yes No Yes No
If yes:
Time limit: Indefinite
999  Years  
Indefinite
999  Years  
Size limit:
 
Threshold for capital or voting power held directly or indirectly by resident in non-resident company 50.00 % 50.00 %
CFC-rules apply if foreign tax rate is lower than
CFC-rules apply for passive income only? Yes No Yes No

Comments   Treaty countries

Comments   Non-treaty countries

The time limit on forward-carrying of losses is infinite. The same applies to the CFC rules.

 
Measures against profit shifting
 
Do Thin Capitalization (TC) rules exist? Yes No
If yes:
Date of first introduction
Introduced as Explicit TC law
Part of CIT law
Test for TC Ratio
Arm's length
If ratio
Value of numerical ratio:
Definition numerator
Definition denominator
 
Debt considered for test Internal
Internal and external
TC depends on shareholding? Yes No
Substantial shareholding threshold
 
Type of shareholding Direct
Indirect
Automatic remedy Yes No
Remedy Non-deductibility of interest
Reclassification as dividend
 
Rules apply to All companies
Foreign companies
Non-EU companies
Transfer pricing rules exists? Yes No
If yes:
Arm’s length principle applied? Yes No
 
Remedy Fee
Tax base increase
 
Tax due date

 
Tax collector

The provisional tax is payable in instalments on 20 March and 20 November of the income year. The final tax is due for payment on 1 November of the year after the income year (when tax is assessed) or on the first day of the month following issue of the demand note. The last day for payment is the 20th of the month in which it falls due.

 
Special features

The rules on assessment, returns and payment laid down in the Corporation Tax Law applied mutatis mutandis.

 
Economic function







Comments

 
Environmental taxes



Comments
 
Tax revenue
ESA95 code d51od (d51bd)

Year
Annual tax revenue (millions)
Currency
Tax revenue as % of GDP
Tax revenue as % of total tax revenue
2011 100.00 DKK 0.01
2010 158.89 DKK 0.01
2009 71.32 DKK 0.00
2008 82.58 DKK 0.01
2007 106.05 DKK 0.01
2006 225.98 DKK 0.01
2005 113.38 DKK 0.01
2004 80.23 DKK 0.01
2003 90.61 DKK 0.01
2002 119.73 DKK 0.01
2001 166.76 DKK 0.01
2000 210.24 DKK 0.02

Comments