Denmark: Parliament passes tax bills concerning shareholder loans and green assets

The Danish Parliament has passed two tax bills aimed at revising shareholder loan taxation and incentivizing green investments.

• Bill L 171: Passed as part of the 2024 Entrepreneurial Package Agreement, this legislation revises tax provisions for shareholder loans and continuous service providers. Key provisions include:
  • Introduction of a tax account system to prevent double taxation on shareholder loans
  • Tax deferral for continuous services, allowing incremental taxation of payments
  • Adjustments to ensure deductions are not claimed for non-depreciable assets and maintaining symmetry between deductions and taxation
  • Effective the day after publication, with specific provisions applying from March 19, 2025, and others from January 1, 2026
• Bill L 195: Passed on June 3, 2025, this bill implements a temporary increase in the depreciation basis for new green assets. Key provisions include:
  • 108% depreciation allowance for new business-use assets acquired between January 1, 2025, and December 31, 2026
  • Exclusion of certain machinery expenses from the enhanced depreciation
  • Effective the day after publication in the Official Gazette

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

Lars Terkilsen | lars.terkilsen@kpmg.com