Take this to your lawyer
Walk in already knowing your options. This is the legal side of your plan in plain words: leaving your country for real, where the company really lives, the treaty discount and its catch, and the EU paperwork question. Every line traces to a checked source, so your first meeting is about your situation, not starting from scratch. It's careful information, not legal advice.
You can get the full picture here
No monopoly on tax advice in Denmark; full product, managed by liability not licensing.
Put together 2026-06-12 · facts current through 2026-09-01 · every legal point below links to its source · redo it free for 90 days from your plan.
Where you see a confidence grade, it scores how good our source is (how official, how recent, how well backed up), not the odds the rule applies to you. "Confirmed" means a strong source, not a guaranteed outcome.
The plan we're checking
Operating company in Cyprus → Cyprus dividends
Leaving Denmark → living in Cyprus
FirstTwo things that decide the answer
Your answers shape the points below and get written into your assumptions, so the note fits your real case.
Will you keep a home you can use in Denmark? Where will the company's real decisions actually get made? 1What you're assuming
You're a tax resident of Denmark today, planning to move to Cyprus.
No separate company in this plan; income lands with you in Cyprus.
These are your words, not facts we checked. If a line is wrong, the rest shifts with it.
You're letting go of your Denmark home — that lines up with leaving cleanly, though you'll still need to show it.
Decisions get made and written down in Cyprus — that supports the company living where you say it does.
2Leaving Denmark for real
Leaving Denmark first triggers its exit tax on unrealised share gains (the gain is taxed at Danish share-income rates of 27%/42%; deferral is possible with security). This is often the largest number in the whole plan, so price it before anything else.
This number only applies once Denmark stops treating you as a tax resident. A home kept available there, or your centre of life, can keep you fully taxable whatever your day count. To leave cleanly: give up available home + cancel CPR; deemed disposal on exit.
To leave Denmark cleanly on the facts we have: give up available home + cancel CPR; deemed disposal on exit
Denmark also charges a tax just for leaving (the gain is taxed at Danish share-income rates of 27%/42%; deferral is possible with security). The euro amount is worked out in the
accountant note; for your lawyer it's a one-off to time around your departure.
3Where the company really lives
No separate company here, so there's no "where does it live" question to settle.
4The treaty discount, and the catch
| From | Income | Treaty rate | What your lawyer checks |
|---|
| United States | dividends | 15% |
That you really own the income (not just passing it through) and that the discount wasn't the main point of the setup. The lower rate only stands if both are true. |
5The EU paperwork question (DAC6)
probably needs reporting
A3 · This is a productized structure with standardised documentation: hallmark A3's definition fits the product itself, before your facts are even considered.
MBT · The engine's own numbers show the tax advantage (+90,604/yr vs staying put) is plausibly the main benefit, which arms the A-category hallmarks.
Likely REPORTABLE under DAC6: an EU member state is involved and the hallmarks above are hit. Who carries the reporting duty (platform, adviser, or you) is a question for counsel before implementation; penalties run per arrangement, per member state.
This check never tells you "you're fine." When the EU is involved it can only raise the question and pass it to a lawyer. It's a heads-up from the facts, not a legal ruling.
6Ask your lawyer
What exactly do I need to do, and keep as proof, to stop Denmark treating me as a resident, so it holds up if they ask?
For the treaty rates below: am I really entitled to them (beneficial ownership, and the "main purpose" test)? What proof do I keep?
If the EU is involved, does this plan need reporting under DAC6, and who has to file it — me, you, or the platform?
Read my assumptions above and tell me which ones don't fit my actual situation.
7Not in this note
The actual tax sums and rates — that's the accountant note.
Visas and the right to actually live where you're going.
Bank checks on where your money came from.
Family, marriage-property and inheritance rules.
Anyone you employ who moves with you.
Who exactly files the DAC6 report (flagged here, decided by your lawyer).
A note that's honest about its edges is more use to a lawyer than one that pretends to cover everything.
8Where these facts come from (62)