Denmark Tax Agency Clarifies Tax Residence Under DTA With U.K.

Sept. 12, 2025, 5:00 AM UTC

The Danish Customs and Tax Administration Sept. 9 posted online Tax Council Binding Answer No. SKM2025.509.SR, clarifying tax residence under the 1980 DTA with the U.K. The taxpayer, an individual, moved from Denmark to the U.K. in 2004, acquired a holiday apartment in Denmark in 2011, and moved back to Denmark in April 2024 after his wife and children moved back in 2023. The Tax Agency found the taxpayer’s full tax liability in Denmark resumed in 2018. Upon review, the Tax Council found that: 1) full tax liability resumed in 2018 because the taxpayer had lived in Denmark since 2011 ...

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