Denmark Tax Agency Clarifies Limited Tax Liability in Transaction Related to Stock Options

The Danish Customs and Tax Administration May 8 posted Tax Council Binding Answer No. SKM2026.230.SR, clarifying limited tax liability for employee stock options. The taxpayer, an employee, received employee stock options under an incentive program, with continuous vesting. The taxpayer later ceased full Danish tax liability while the options continued to vest and then exercised the options abroad. The taxpayer sought clarification on whether the vested stock options were subject to exit taxation and whether options exercised after relocation remained subject to Danish limited tax liability. Upon review, the Tax Council found that: 1) the vested stock options were subject ...