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Denmark: Proposed changes to tax law in legislative program

Proposed changes within the area of tax law as part of the legislative program for the year 2024-2025

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November 14, 2024

The Danish government has proposed changes within the area of tax law as part of its legislative program for the year 2024-2025. The program includes a number of proposed changes aimed at implementing the government's entrepreneurship strategies announced earlier in 2024.

Tax reductions for the entrepreneurial sector

  • Removal of dividend taxation for unlisted portfolio shares
  • Increase in the cap for deposits on share savings accounts
  • Taxation upon disposal of newly listed portfolio shares
  • Increase in the progressive threshold for share income
  • Increase in tax credit for research and development (R&D) expenses
  • Gross tax scheme for foreign researchers
  • Increase in the deduction limit for carried forward losses

Changes in depreciation on software, know-how, and patent rights

  • Removal of immediate depreciation for software acquired from January 1, 2025
  • Removal of immediate depreciation for know-how, patent rights, and related rights acquired from January 1, 2025
  • Permanent increase of the R&D deduction to 120%

Changes in foundation taxation

  • Taxation of unutilized provisions
  • Adjustment of the distribution obligation
  • Elimination of losses in tax-free mergers
  • Tax exemption for certain interest

Commitments to introduce future bills

  • Generational transfers
  • Easing the taxation of shareholder loans
  • Amendment of the minimum taxation
  • Transfer pricing rules adjustments
  • Tax treatment of gains and losses on cryptoassets


Read a November 2024 report prepared by the KPMG member firm in Denmark


For more information, contact a KPMG tax professional in Denmark:

Lars Terkilsen | lars.terkilsen@kpmg.com

Caroline Bormlund Thomsen | caroline.b.thomsen@kpmg.com

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