Quick answer — leaving Denmark with an ApS. If you have been fully taxable in Denmark for at least 7 of the last 10 years and your shares are worth more than DKK 100,000, Denmark taxes the unrealised gain on your shares when you move abroad, as share income at 27% and 42%. Payment can usually be deferred, with annual reporting. Your ApS stays a Danish company taxed at 22%, and dividends to non-residents face Danish withholding tax, reduced by treaty.
Executive Summary & Context
The ApS is the standard Danish private limited company, used by founders, consultants and freelancers alike. When the owner moves abroad, Denmark's exit tax on shares (fraflytningsbeskatning) applies to the value built up in the company, and the ApS itself continues as a Danish taxpayer.
The Danish model is relatively founder-friendly in one respect: you can generally defer the exit tax rather than pay it on departure. But the deferred amount stays on record, dividends and sales can reduce or trigger it, and you must report each year. Understanding how the deferral works is essential before deciding to keep the ApS.
Who this guide is for
- ApS founders, consultants and freelancers leaving Denmark to become location-independent or settle abroad.
- Owners of growing Danish startups with significant unrealised value.
Who it is not for
This guide does not cover owners staying in Denmark, employees posted abroad, cross-border commuters, or settled expats. For your personal move, see our relocation guides.
For other countries and the general framework, see our overview on relocating your business abroad.
Legal Entities & Comparison Matrix
| Option | What happens | Tax consequences | Works best when |
|---|
| Keep the ApS | It stays Danish; you remain director from abroad or appoint a Danish director | Exit tax on your shares, usually deferred; Danish corporate tax continues; dividend withholding | Danish clients, staff or significant value |
| Liquidate the ApS | Solvent liquidation | Liquidation proceeds taxed as share income | The business is personal and can restart abroad |
| Sell the shares | Sale before departure | Gain taxed as share income | There is a buyer |
| Restructure | Move the business to a foreign company or transfer assets | Corporate exit taxation of hidden reserves | You will run the business from abroad long term |
Key Danish rates
| Tax | Rate |
|---|
| Corporate income tax | 22% |
| Share income (dividends and gains) for individuals | 27% up to an annual threshold, 42% above |
| ApS minimum share capital | DKK 20,000 |
| Dividend withholding for non-residents | 27%, reduced to the treaty rate by refund or at source |
Also relevant: the Swedish AB after emigration and the Dutch BV seat transfer.
Substance, Residence & Compliance Governance
Denmark's exit tax on shares
The exit tax applies when you cease to be fully taxable in Denmark if:
- you have been fully taxable in Denmark for at least 7 of the last 10 years; and
- the market value of your shares exceeds DKK 100,000.
The gain is computed as if the shares were sold at market value on the day you leave and is taxed as share income.
Deferral: you can generally apply for a deferral of payment (henstand). You then report annually on the shares you still hold. Dividends received and sales of shares reduce or trigger the deferred tax. Check the current conditions, as Denmark has tightened them over time.
Where your ApS is taxed after you leave
An ApS registered in Denmark is a Danish taxpayer. If you manage it from your new country, that country may claim it is resident there or has a permanent establishment there; the tax treaty decides.
Paying yourself as a non-resident
- Dividends face 27% Danish withholding tax, reduced to the treaty rate, sometimes only through a refund claim.
- Director's fees from a Danish company can remain taxable in Denmark under many treaties. Social security depends on EU coordination rules or bilateral agreements.
Administration
Report your move to the Danish civil registration system, file your final tax return with the exit tax calculation and deferral request, and keep the ApS's annual report, tax returns and register filings up to date.
Setup Costs & Economic Model
| Cost item | Indicative amount (2026) | Notes |
|---|
| Share valuation for the exit tax | DKK 10,000–60,000 | Needed for the deemed sale |
| Tax adviser for the final return and deferral | DKK 8,000–30,000 | |
| Annual deferral reporting | Often part of the adviser's annual fee | Required while the tax is deferred |
| Ongoing ApS accounting and annual report | DKK 20,000–60,000 a year | Unchanged after you leave |
| Liquidation (if closing) | DKK 10,000–30,000 | Solvent liquidation procedure |
Amounts are indicative.
The economic model: an ApS worth DKK 2 million
| Step | Amount |
|---|
| Market value of the shares on departure | DKK 2,000,000 |
| Acquisition cost | DKK 40,000 |
| Gain | DKK 1,960,000 |
| Exit tax as share income (27% on the first band, 42% above) | roughly DKK 800,000 |
| Payable immediately with deferral | Nil, subject to the deferral conditions |
The deferred tax stays on record. Dividends from the ApS and sales of shares after you leave will reduce or trigger it, so plan your distributions with this in mind.
Step-by-Step Formation & Business Banking
- Value your ApS shares as of the planned departure date.
- Check whether the exit tax applies: 7 of the last 10 years fully taxable, and shares worth more than DKK 100,000.
- Compare keep, liquidate, sell and restructure, including future Danish corporate tax versus a company in your new country.
- Plan distributions before and after departure, considering the deferral rules and withholding tax.
- Read the tax treaty with your new country for company residence, dividends and director's fees.
- Report your move and file your final return with the exit tax calculation and deferral request.
- Set up annual deferral reporting for as long as you hold the shares.
- Update the business register and your bank with your new address and tax residence.
- Register in your new country and obtain a tax residency certificate.
Business banking after you leave
Danish banks generally keep the ApS account but will update KYC. Digital identification (MitID) for non-residents can be a practical issue; sort out access before you leave.
The Denmark Founder Exit Guide covers the timeline, deferral and filings — get it when you plan your ApS's exit with Heavnn.
Frequently Asked Questions (FAQ)
Does Denmark have an exit tax on company shares?
Yes. If you have been fully taxable in Denmark for 7 of the last 10 years and your shares are worth more than DKK 100,000, Denmark taxes the unrealised gain when you move abroad.
Can the Danish exit tax be deferred?
Generally yes. You can apply for a deferral of payment and then report annually. Dividends and sales of shares reduce or trigger the deferred amount.
Does my ApS stay Danish if I move abroad?
Yes. An ApS registered in Denmark stays a Danish taxpayer. Your new country may also claim it if you manage it from there.
How are dividends from my ApS taxed after I leave?
Denmark withholds 27% on dividends to non-residents, reduced to the treaty rate at source or through a refund. Your new country then taxes them under its rules.
What is the minimum capital of a Danish ApS?
The minimum share capital of an ApS is DKK 20,000.
Plan Your ApS's Exit with Heavnn
Denmark's exit tax can usually wait, but it doesn't disappear. Heavnn plans the deferral and your distributions together.
- Get the Denmark Founder Exit Guide for the timeline, deferral and filings.
- Then find out whether you can defer the Danish exit tax and how to take dividends after you leave.
Plan your company's exit with Heavnn →
This guide is general information, not tax or legal advice. Rules are summarised as of October 2026.
