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EU holding companies routing global subs, Denmark

Denmark's participation exemption removes corporate tax on dividends and capital gains from qualifying subsidiaries (10% or more ownership for one year, broader categories), and the 80+ DTA network plus EU Parent Subsidiary Directive give clean repatriation. ApS at DKK 40,000 paid in capital or A/S at DKK 400,000 fit different scales.

Participation exemption80+ DTAsEU PSD 0%
Start setup {placement} 4 min · no card required
Corp tax
22%
Fastest setup
1-3 days
Tax treaties
80
Region
Europe

What you'll need

  • No resident director required
  • Local registered office required
  • Economic-substance test applies
  • Minimum capital: DKK 20,000
  • Administrative language: Danish (English widely accepted)
  • Legal system: Civil law

Tax and treaty profile

  • Corporate tax 22%
  • Tax treaties 80
  • VAT rate 25%
  • Withholding on dividends 27%
Key treaty partners
GermanySwedenNorwayUKUSANetherlands

Banking and payments

  • Banking takes 2 to 4 weeks with KYC
  • Stripe supported
  • Wise supported
  • Crypto banking available
  • EMI license framework available

Considerations

If you want to minimise paid in capital

A/S requires DKK 400,000 paid in capital; ApS lowers this to DKK 40,000 but is unfamiliar to some institutional counterparties. There is no statutory minimum below ApS. For lower capital and similar EU passport:

A/S DKK 400,000 paid inApS DKK 40,000 paid inNo EUR 1 vehicle