A closer look
To qualify as an equity-based investment company, an investment fund must fulfill the following requirements:
Initial notification
Initial notification to the Danish tax authorities must be made no later than 31 October before the calendar year for which the registration should take effect.
Therefore, initial notifications for 2025 should be filed before 31 October 2024.
Annual reporting
The investment fund must invest at least 50% of its assets in equities as defined by the Danish rules. To prove compliance, the investment fund must compile an asset test on at least four evenly distributed dates of the calendar year and submit this asset test information annually to the Danish Tax Authorities before 1 July of the following year.
Accordingly, the asset test information for a 2025 notification should be submitted before 1 July 2026
Qualification as opaque
The fund must qualify as opaque (or non-transparent) for Danish tax purposes. While corporate-based investment funds should typically fulfill this requirement, funds structured on a contractual basis may need an individual assessment.
The list of funds that have applied for this fund tax regime, and are considered equity-based investment companies from 2024 (Liste over aktiebaserede investeringsselskaber 2024), is available on the Danish tax authorities’ website.
