Denmark Tax Agency Clarifies Exit Tax, Individual Income Taxation of Pensions Under DTA With Greenland

The Danish Customs and Tax Administration June 12 posted online Tax Council Binding Answer No. SKM2026.282.SR, clarifying exit tax and individual income taxation of pensions under the 1979 DTA with Greenland. The taxpayers, partners in a Danish dental clinic, sought to sell the clinic, move to Greenland, work a few years, then retire there. The taxpayers inquired as to exit tax and pension taxation. Upon review, The Tax Council found that: 1) exit tax wouldn’t be due on the clinic’s value upon leaving Denmark because the clinic would be a permanent establishment (PE); 2) the profit on selling the clinic ...