Denmark Tax Agency Clarifies Taxation of Payments From Swiss Pension, Insurance Regimes

The Danish Customs and Tax Administration March 20 posted online National Tax Court Decision No. SKM2026.146.LSR, clarifying the taxation of payments from Swiss pension and insurance regimes. The taxpayer, an individual, received several payments in 2010-2011 from Swiss Pillar Two occupational pension funds and an international retirement guarantee regime after moving to Denmark. The Tax Agency treated the amounts as taxable under the Pension Taxation Act. The taxpayer argued that the amounts were legally acquired before Danish tax residency and were non-taxable. On appeal, the National Tax Court found that: 1) the pension payments were covered by Section 53B, making ...