Danish fund tax regime : 2026 registration due by 31 October 2025

At a glance

Any foreign investment funds interested in the Danish retail market should check whether they qualify as equity-based investment companies under Danish tax rules and should register under the tax regime for the following year before 31 October (e.g., by 31 October 2025 for 2026 benefits).

Additionally, the creation of new share classes or closure of existing ones must also be registered with the tax authorities within two months of their creation or closure.

The Danish fund regime, which has applied since 2020, was introduced to make foreign funds more attractive to individual Danish investors. Under this regime, the yield on “equity-based investment companies” is taxed as “share income” instead of “capital income,” resulting in lower tax rates that apply within certain brackets.

A closer look

To qualify as an equity-based investment company, an investment fund must fulfill the following requirements:
 

Initial notification

You must notify the Danish tax authorities no later than 31 October to ensure the registration takes effect in the following calendar year.

Therefore, initial notifications for 2026 should be filed before 31 October 2025.
 

Annual reporting

The investment fund must invest at least 50% of its assets in equities as defined by the Danish rules. To prove compliance, the investment fund must compile an asset test on at least four evenly distributed dates of the calendar year. They must then submit this annual asset test information to the Danish tax authorities before 1 July of the following year.

Therefore, asset test information for a 2025 notification should be submitted before 1 July 2026. Accordingly, the asset test information for a 2026 notification should be submitted before 1 July 2027.
 

Qualification as opaque

The fund must also qualify as opaque (or non-transparent) for Danish tax purposes. While corporate-based investment funds should typically fulfill this requirement, funds structured on a contractual basis may need an individual assessment.

The list of funds from 2025 that have applied for this fund tax regime, and are considered to be equity-based investment companies, is available on the Danish tax authorities’ website. 

How Deloitte can help 

Deloitte can help you with registering your funds and share classes as equity-based investment companies, as well as with calculating and submitting the required asset test information within the required deadlines.