If you recruit researchers and highly paid employees from abroad, they may under certain conditions choose to pay tax at a rate of 27% plus labour market contributions, totalling 32.84%, for a period of seven years.

These researchers and highly paid employees are not entitled to tax deductions or allowances of any kind.

  • If you employ non-Nordic or non-EU labour, you need to ensure that the employee has a valid residence and work permit. You can do so by contacting the Danish Immigration Service for example.

  • The tax liability in Denmark takes effect when the employee starts receiving income from working in Denmark.

  • The researcher must not have been fully liable to taxation in Denmark or subject to limited tax liability in Denmark on earned income etc. or business income within the last 10 years prior to employment.

    However, income from guest lecturing activities or the like at a university or research institution is accepted if it has been generated over a period of a maximum of 12 months within the past ten years.

  • The researcher may have been subject to full tax liability on income from guest lecturing activities or the like for a maximum of 12 months as long as it is foreign income.

  • The qualifications of the researcher must be approved by a public research institution or the Independent Research Fund Denmark (Danmarks Frie Forskningsråd) and the researcher must engage in research.

Application for approval of research qualifications (Please note that the link is in Danish).

Form 01.012 A - Registration of approved researcher

For further information, see Tax scheme for foreign researchers and highly paid employees.

  • If you employ non-Nordic or non-EU labour, you need to ensure that the employee has a valid residence and work permit. You can do so by contacting the Danish Immigration Service for example.

  • The tax liability in Denmark takes effect when the employee starts receiving income from working in Denmark.

  • The employee may not have been subject to full tax liability in Denmark or liable to limited tax liability in Denmark on salary or business income etc. within the last 10 years prior to the employment.

  • The employee may not have been directly or indirectly involved in the management of the business or control over the business or have had essential influence on the business within the last five years prior to employment.

  • In 2019, the average monthly salary must be at least DKK 66,600 (DKK 65,100 in 2018) within the calendar year after deduction of labour market supplementary pension fund (ATP) contributions. Please note that when coming to Denmark, the new employee has still not earned the right to holiday pay. As a result, since any holiday taken by the employee is unpaid, he/she may not fulfil the minimum salary requirement. Please also note that the employee’s own contributions to a pension scheme with tax exemption will not be included when we assesses if the salary requirement has been fulfilled. Nor will any non-guaranteed pay such as bonuses. The minimum salary must be guaranteed in the employment contract before employment commences and before a new rate comes into force at the turn of the year. Please note that no exemptions can be made to this requirement. However, before the end of the year, a supplementary agreement to the contract may be made to guarantee the minimum salary.

Form 01.012 B - Registration of approved highly paid employee

For further information, see Tax scheme for foreign researchers and highly paid employees.

What you as an employer must be aware of when you have employees covered by the gross tax scheme

The scheme applies to:

  • Highly paid employees who are covered by the requirement for minimum salary
  • Researchers who have been approved by the public research institution at which they are employed
  • Researchers who have applied for approval from the Independent Research Fund Denmark (Danmarks Frie Forskningsråd) no later than one month after the beginning of the employment and who have been approved.

Your business and the employee are responsible for ensuring that all the conditions for being taxed under the gross tax scheme are met at all times. The Danish Tax Agency may at any time check whether the conditions are met.

Procedure when registering the employee

  1. Apply for registration of the employee under the gross tax scheme.
  2. You will receive a letter confirming receipt of the application from the Danish Tax Agency. You can expect the case to be considered within 6 months after you received the personal tax number. If the employee does not already have a personal tax number, you must send a request for a personal tax number along with the application. We can create a personal tax number 21 days before the beginning of the employment at the earliest. Subsequently, you will receive a ‘Meddelelse om dansk skattepersonnummer' (Notification of Danish personal tax number).
  3. You will receive notification of the employee's registration under the researcher scheme.

If the employee has a civil registration number/personal tax number, you can report salary to be taxed under the gross tax scheme. This can also be done even though we have not yet registered the employee as covered by the gross tax scheme. If it turns out that the employee cannot be covered by the gross tax scheme, both your business and the employee are liable for the outstanding A-tax.

What is required in order for the employee to get a correct tax assessment notice

  1. The Danish Tax Agency registers the employee as being covered by the scheme.
  2. Report the salary in the E-income system with the type of income (Beskæftigelseskode (Employment code)) ‘08'. You must withhold 8% labour market contribution, labour market supplementary pension contribution (ATP contribution) and 27% A-tax. In addition to the employment code, you must report the salary in the same fields as for other employees. You do not need to download a tax card.
    If you have any questions about salary to employees (E-income), please call (+45) 72 22 28 24 direct.
  3. Report the salary under the CVR number or SE number registered for the employee.
  4. Report all salary and holiday pay for the period during which the employee is covered by the gross tax scheme. If you report salary outside the period during which the employee is covered by the gross tax scheme, this salary will be taxed according to the general rules.

When the employment ends: Please note that any holiday pay must be reported in the last month during which the employee is covered by the gross tax scheme.

Taxation under the scheme and taxation in accordance with the general Danish tax rules

The labour market contribution and gross tax are calculated on the basis of the employee's A-income from the business. The employee is not entitled to any tax deductions or allowances when calculating the gross tax.

Contributions to a taxable pension (section 53 A of the Danish Pension Tax Act (Pensionsbeskatningsloven)) are also included in the remuneration which is taxable under the gross tax scheme. You as the employer must withhold the tax and the contribution.

B-income, such as free accommodation and free food etc., is not covered by the gross tax scheme, but is taxed in accordance with the general Danish tax rules. A preliminary income assessment must be created for the employee indicating this income.

In the same way as other employees, employees covered by the gross tax scheme can get a tax-free allowance to cover food, accommodation and transport expenses in accordance with the general rules.

If the contract is changed

If the contract is changed, you must send a copy of the new contract to us. You must also notify us if the employee chooses to withdraw from the scheme or resigns from the position at a different time than the time previously stated by you.

The employee may be covered by the gross tax scheme for one or more periods with a total duration of a maximum of 84 months.

Special conditions for researchers and highly paid employees

Highly paid employees
As an average for 2018, the employee's gross income must amount to a minimum of DKK 65,100 (DKK 63,700 in 2017) per month after deduction of ATP contributions. The amount is subject to annual indexation, and you can keep up-to-date under the header 'Conditions for highly paid employees' on this page.

The following income is included in the calculation of A-income:

  • Money in the form of, for example, salary, holiday benefits, fees, bonus and commission
  • When your business covers the employee's private expenses for, for example:
    • own home/rented accommodation
    • moving
    • school
    • own telephone
  • The following employee benefits are considered A-income and must be taxed under the scheme:
    • company car
    • free telephone
    • paid health insurance and paid health treatment
  • Contributions to a taxable pension (section 53 A of the Danish Pension Tax Act). The employer is responsible for withholding the labour market contribution and the tax on the pension contribution.

Researchers employed by universities or other public research institutions

Certain universities and public research institutions can approve the employee's qualifications as a researcher themselves.

The employment of the researcher must comply with the definition of researcher in the relevant job structure circular. The statutory rules are described in Danish in section 48 E of the Withholding Tax Act (Kildeskatteloven), Executive Order no. 216 of 1 March 2013.

Researchers employed by an employer which is NOT a public research institution

Registration of the employee is carried out on condition that the employee's qualifications as a researcher have been approved by the Danish Council for Independent Research and that the researcher engages in research. It is a condition that the researcher has applied to the Danish Council for Independent Research within one month of the beginning of the employment.

Please note that if the contract is changed, renewed approval must be obtained from the Danish Council for Independent Research.

Please see our legal guide (in Danish) for further legal information.