Denmark

Taxable period

Danish corporate taxpayers are taxed on an annual basis. Corporate taxpayers may choose a tax year that is different from the calendar year.

Tax returns

Tax returns are completed on the basis of financial accounts with adjustments for tax. Tax returns should be filed no later than six months following the end of the accounting year. Corporations with an accounting year-end that falls in the period from 1 March to 31 March must file a tax return no later than 1 September in the same calendar year.

Tax returns must be filed digitally. Companies can file the tax return themselves or grant their auditor/tax advisors access to file the tax return on their behalf.

The tax system, in practice, is based on self-assessment. Tax assessments are made automatically by the tax authorities on the basis of the tax return. However, the tax authorities may subsequently audit the tax return.

Payment of tax

CIT must be paid on a current-year basis in two equal instalments due on 20 March and 20 November. The authorities request payments of 50% of the average of the last three years’ final income tax. In addition, voluntary additional payments may be made on the same dates. Companies may make a voluntary additional payment no later than 1 February following the assessment year (i.e. no later than 1 February 2024 for the tax year 2023 and no later than 1 February 2025 for the tax year 2024).

For voluntary advance tax payments made no later than 20 March, the company is granted an allowance of 1.1% (2024), while voluntary advance tax payments made no later than 20 November are imposed a surcharge of 1.1% (2024). Additional voluntary advance tax payments made after 20 November but no later than 1 February in the year following the income year are imposed a surcharge of 1.6% (2024).

In case of voluntary and ordinary advance tax payments made no later than 20 November exceeding the final tax bill, an allowance of 4.4% (2024) is granted on the overpaid amount. In case of the final tax bill exceeding advance tax payments, a surtax of 8.3% (2024) is charged on an amount reflecting the difference between the advance tax payments and final tax bill.

The final tax bill is settled on 20 November in the year following the income year. Underpaid tax, including the surtax of 8.3% (2024), is then payable, and overpaid tax, including the allowance of 4.4% (2024), is refunded.

The allowance percentage, surcharge percentages, and surtax percentage are published by the Danish tax authorities no later than 15 December of the income year.

Tax audit process

The Danish tax system is based on self-assessment. Companies are, in general, subject to audit on a random basis, but some large companies/groups are subject to annual audit by the Danish tax authorities.

Statute of limitations

The general statute of limitations is 1 May in the fourth calendar year after that of the end of the relevant accounting period. The deadline concerns the tax administration’s notification of making or changing an assessment of income tax. This limitation is extended for another two years with respect to inter-company (transfer pricing) issues and certain tax-exempt restructurings.