The Danish Ministry of Taxation has published the new salary threshold for the expat tax scheme.
From 1 January 2027, the monthly threshold increases to DKK 67,300 excluding ATP, up from DKK 65,400 excluding ATP in 2026. Companies with employees on the scheme should therefore review their salary packages before the end of the year.
If the salary requirement is not met, the employee may lose access to the scheme and will instead be taxed under the ordinary Danish tax rules.
Who must meet the salary requirement?
The salary requirement applies to highly paid key employees who wish to use the scheme.
Under the employment contract, the employee must be guaranteed remuneration that, as an average within the same calendar year, is at least equal to the threshold. The employee's own ATP contribution is payable in addition.
Approved researchers are not subject to the salary requirement.
What counts towards the salary requirement?
The salary requirement must be met through contractually guaranteed remuneration, averaged within the same calendar year.
In addition to cash salary, certain taxable remuneration components and benefits can be included, such as a cash housing allowance, a company car, taxable employer-provided telephone and internet access, and employer contributions to a pension scheme under section 53 A of the Danish Pension Tax Act.
Only a contractually guaranteed bonus of a specified amount, to which the employee becomes entitled within the calendar year, can be included when assessing the salary requirement. This could, for example, be a sign-on bonus if it meets the conditions.
A non-guaranteed bonus cannot therefore be used to meet the salary requirement, even if it is paid and brings the average monthly remuneration for the year above the threshold.
Other conditions
The scheme allows approved researchers and highly paid employees to be taxed at an effective rate of 32.84% for up to seven years.
This consists of an 8% labour market contribution followed by 27% tax on the remaining amount.
In addition to the salary requirement, a number of other conditions must be met:
- Previous Danish tax liability: As a general rule, the employee must not have been fully tax liable in Denmark or subject to certain types of limited Danish tax liability during the preceding ten years.
- Employment relationship: The employee must be employed by an employer that meets the Danish tax liability requirements, such as a Danish company or a foreign company's permanent establishment in Denmark.
- Arrival in Denmark: As a general rule, the employee must not move to Denmark more than one month before the first working day.
- Ownership and influence: The employee must not have, or have had during the preceding five years, significant direct or indirect influence over the employer.
For companies, this means that the employee must not own 25% or more of the share capital or control more than 50% of the voting rights. Shareholdings held by close family members must also be taken into account. - Approval of researchers: Where the scheme is used by a researcher, the employee's qualifications and research position must be approved under the applicable rules.
Grant Thornton’s recommendation
Employers should check now whether employees' guaranteed remuneration meets the published salary requirement for 2027.
For employees already covered by the scheme, a salary increase can be agreed during 2027, for example if the annual salary review takes place after year-end. This is subject to the contractually guaranteed average monthly remuneration for the 2027 calendar year meeting the salary requirement.
We recommend agreeing and documenting any necessary contract amendments as soon as possible. If the salary increase is agreed after year-end, we recommend making it effective from 1 January 2027.
The amendment should clearly document the guaranteed remuneration and ensure that the employee meets the salary requirement for the calendar year.
Reservation for the 2027 income year
For the 2027 income year, we make a specific reservation that the published threshold may change if the announced plans to freeze rates and thresholds are implemented.
Need advice?
Unsure what the new salary requirement means for your use of the researcher tax scheme? We can help you get an overview of the rules and what they mean for you.
