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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Double Taxation Relief Manual: Guidance by country: Denmark: Pensions

Pensions, other than government pensions, are normally taxable in the country where the pensioner is resident.

However, Denmark is entitled to tax employment pensions paid to a United Kingdom resident who has at some time previously been a resident of Denmark. Such pensions are also taxable in the United Kingdom and credit can be given for any Danish tax charged on the same pension. Where the individual moved to the United Kingdom prior to 12 March 1997 and who on that date was in receipt of a pension which falls within the scope of Article 18(2), Denmark, under its domestic law, will exempt pension payments up to an amount of DKK200,000 and only charge tax on any excess. It is only the Danish tax on the excess that qualifies for credit relief in the United Kingdom.

Danish social security pensions are taxable only in Denmark and are not taxable in the United Kingdom.

Different provisions applied for periods up to 31 December 1997. Advice can be sought from the Tax Treaty Team in relation to years before 1998.