Danish fund tax regime: 2027 registration due by 31 October 2026

At a glance

Foreign investment funds targeting the Danish retail market should assess whether they qualify as equity-based investment companies under Danish tax rules and register under the tax regime for the following year by 31 October (e.g., by 31 October 2026 for 2027 benefits).

New share classes and closures must also be reported to the Danish tax authorities within two months from their creation or closure, respectively.

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 meet 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 2027 should be filed by 31 October 2026.

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 perform an asset test on at least four dates evenly distributed throughout the calendar year. The fund must then submit this annual asset test information to the Danish tax authorities before 1 July of the following year.

Therefore, the asset test information for 2026 should be submitted before 1 July 2027, while the asset test information for 2027 should be submitted before 1 July 2028.

Qualification as opaque

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

List of qualifying funds

The list of funds that applied for the regime in 2026 and were considered equity-based investment companies is available on the Danish tax authorities’ website. 

Deloitte can help you register your funds and share classes as equity-based investment companies. Our professionals can also support you in calculating and submitting the required asset test information within the applicable deadlines.