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Generic Tax Name Hydrocarbon tax
Tax name in the national language Kulbrinteskat (skat af kulbrinteindvinding)
Tax name in English Hydrocarbon tax
Member State DK-Denmark
Tax in force since 1982/04/28
If abolished, date on which the tax ceases to apply
Business version date 2015/01/01
Version date 2015/02/17
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

Laws on assessment and collection of hydrocarbon tax, see Statutory Notice No 862 of 9. June 2014 (Kulbrinteskatteloven).

 
Who sets
The tax rate is set by




The tax base is set by




The reliefs are set by




Comments
 
Beneficiary





Comments

 
Geographical Scope

 
Taxpayers
  • Individuals, estates, corporations, etc., which derive income from the extraction of hydrocarbons in Denmark.
  • Individuals, estates, corporations, etc., which do business or earn wages or the like in connection with the extraction of hydrocarbons in Denmark, and which are not liable to tax in Denmark under the ordinary income tax rules.
 
Tax object and basis of assessment

Companies that have income deriving from the extraction of hydrocarbons pay corporate income tax to the State, and hydrocarbon tax as a supplement to that tax. Persons calculate tax of such income in the same way as corporations. The corporate income tax is assessed under the general rules of tax legislation.

However, the following special rules apply:

  • Hydrocarbon income (defined by a ‘ring fence') is calculated separately
  • Losses may be deducted wholly or partly from other income, but losses from other income sources may not be deducted from hydrocarbon income
  • The law allows the Minister of Transport and Energy to fix "norm prices" for the purpose of determining taxable income
  • Exploration expenses can always be deducted in the year incurred.
  • Recognition of income realized in connection with a farm-out agreement can be postponed up to 3 years.

The hydrocarbon tax is an additional profits tax. The basis of assessment for the hydrocarbon tax is calculated separately. The rules applied are basically the same as those used in calculating the corporate income tax due on hydrocarbon income. There are exceptions made, however:

 

Rules for licenses issued after 1 January 2004 (including the Sole Concession) and Licenses issued prior to 1 January 2004 were harmonized from 2014 (with certain transition rules for licenses that went from old to new rules):

  • Hydrocarbon income is the sum of income from all fields (no specific field income is calculated)
  • The "hydrocarbon tax allowance" is 5 pct. over 6 years
  • Corporate income tax of hydrocarbon income is deductible
  • The hydrocarbon tax is 52 pct.
  • The tax value of remaining losses will be paid to the company when activity with extraction of hydrocarbons is finally ceased to the extent the tax value does not exceed the hydrocarbon tax paid by the company in earlier years.

 

The law also affects the taxation of individuals who are not affected by the ordinary tax laws:

Individuals who are not fully or limited liable to Danish income taxation and who derives income from commercial business connected with hydrocarbon activity on Danish soil - except income from the extraction of hydrocarbon income - pays income tax with 25 pct. (equivalent to the corporate tax rate and the supplement tax on hydrocarbon income).

Individuals who are not fully liable to Danish income taxation, and who are employed by a foreign employer, pays a final withholding tax on 30 pct. of wages or salaries in connection with hydrocarbon extraction without any deductions. The individual may choose taxation according to the ordinary income tax rules (as limited liable to Danish income taxation).

 
Deductions, Allowances, Credits, Exemptions

See "Basis of assessment".

 
Rate(s) Structure

See "Basis of assessment".

 
Tax due date

The tax is due to payment in installments 1 October of the income year and 1 June of the following income year. The last day for payment is the 20th of the month in which the payment is due. The first installment is calculated as half the expected tax payment for the ongoing income year. The second installment is calculated as the difference between the final tax payment and the first installment.

 
Tax collector

 
Special features

See "Basis of assessment".

 
Economic function







Comments
 
Environmental taxes



Comments
 
Tax revenue
ESA95 code d51oc +d51oe (d51bc + d51be)

Year
Annual tax revenue (millions)
Currency
Tax revenue as % of GDP
Tax revenue as % of total tax revenue
2012 20,771.00 DKK 1.10
2011 19,005.47 DKK 1.04
2010 15,788.25 DKK 0.88
2009 12,342.11 DKK 0.72
2008 23,030.74 DKK 1.28
2007 18,627.05 DKK 1.07
2006 20,593.73 DKK 1.22
2005 15,282.84 DKK 0.96
2004 9,834.61 DKK 0.65
2003 6,170.11 DKK 0.43
2002 6,239.37 DKK 0.44
2001 5,781.09 DKK 0.42
2000 5,955.15 DKK 0.45

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