Fuld og begrænset skattepligt: Den danske skattepligt når fysiske personer flytter til og fra Danmark

Merete Andersen

Student thesis: Diploma thesis


Tax in Denmark is simple, right from birth we are Dane fully taxable to the country, and in most cases the tax liability will cease only when we mortify. But is it always so simple - of course not. The Danes are the result of increased globalization has begun increasingly to move across national borders, and here the Danish taxpayer more complicated. The main topics of this project are tax by immigration and emigration from Denmark. The project looks at when the Danish tax liability starts and ends. What kept the tax liability standby while we are abroad and when foreign nationals captured by the full Danish tax liability. In Denmark, there are special tax rules in the recruitment of researchers and other key personnel, this look in a portion closer to the project. The project will also map onto the Danish tax on the frontier, the Danish social security and the situation where a taxpayer is taxed twice, how this can be relaxed taxpayer to double taxation. The project addresses the situation where a Danish taxpayer is leaving Denmark. Tax liability continues in Denmark, where the taxpayer simply leave the country for less than 3 years to work abroad, while if the stay abroad is taking longer than 3 years can be obtained tax exemption if certain conditions are met. Taxpayer who is leaving Denmark hero must show by their actions they intend to leave the country to take permanent residence in another country. Further looks at the situation where a foreign taxpayer is coming to Denmark. When there is no tax liability to Denmark, when the person is limited tax liability in Denmark, and what it implies, and finally when a foreign taxpayer is captured by the Danish full tax liability. To the extent that a foreign taxpayer is coming to Denmark, looks too closely at the special Danish system is the research and other key persons in which persons under this scheme can achieve a gross tax of only 26%. It is not uncommon in these situations where the taxpayer moves across borders, the taxpayer might be the consequence to be double taxed. Both the Danish tax law and the OECD Model Convention incorporate rules for relief from such double taxation. The relaxation can occur by two methods - credit method or the Exemption Method. The project should like to give pay and HR staff a tool to guide staff on “udstationering” and “Indstationering”.

EducationsGraduate Diploma in Accounting and Financial Management, (Diploma Programme) Final Thesis
Publication date2012
Number of pages78