How corporate tax works in Denmark
Denmark taxes resident companies on worldwide income at a flat 22%. There is no municipal or regional corporate surcharge, which keeps the headline equal to the effective rate for most firms.
Dividends and capital gains on subsidiary shares of 10% or more are generally exempt. Portfolio holdings follow mark-to-market or realisation rules depending on the asset and election.
Groups with global turnover above EUR 750 million face the 15% Pillar Two minimum through Danish IIR, qualified domestic top-up and UTPR rules. Losses carry forward without time limit, with some restrictions on change of ownership.
Tax rates at a glance
- Corporate rate
- 22%Flat
- Subsidiary exemption
- 10%+
- Pillar Two minimum
- 15%
- Loss carry-forward
- Unlimited
Who benefits most
These profiles tend to benefit most when the rules match their real residence, payroll and business setup.
FoundersHolding companiesRegional operatorsInvestorsCross-border groups
Watch out for
- Denmark is cheap for companies and costly for their staff. A 22% corporate rate next to 56% top salary tax pushes founders toward dividend and capital planning.
- Interest deduction caps, EBITDA rules and thin-capitalisation tests limit debt push-downs. Danish financing structures need modelling, not assumptions.
- Withholding on outbound dividends, interest and royalties varies by treaty and EU directive. Check the recipient's status before pricing distributions.
- Transfer pricing documentation is mandatory for larger cross-border groups, with strict deadlines and penalties.
Frequently asked questions
Does Denmark have corporate tax?
Yes, a flat 22% on company profits with no local surcharge.
Are subsidiary dividends exempt in Denmark?
Generally yes for holdings of 10% or more. Portfolio dividends follow different rules.
Does Pillar Two apply in Denmark?
Yes. Denmark enacted the EU minimum-tax directive, so groups above EUR 750 million turnover face a 15% floor.