New double tax treaty between Denmark and France

On March 23, 2023, Denmark passed L17 2022/2023 and thereby introducing (again) a double tax treaty between Denmark and France. The new double tax treaty will address the taxation of pensions and strengthen the economic relations between the two countries. The agreement comes after years of negotiations and will replace the previous agreement, which Denmark terminated in 2008 due to issues with the taxation of Danish pensions in France.

The new tax treaty ensures that Denmark has the right to tax payments from pension schemes where Denmark has provided a tax deduction for contributions as the tax treaty also includes an “inverted credit” principle, meaning Denmark will grant relief for the tax paid in France against the tax payable in Denmark. Besides the “inverted credit” principle, the double tax treaty is generally following the principles of the OECD Model Tax Convention.

Even though the double tax treaty has been introduced, the time when the double tax treaty will come into force will await confirmation from the Danish Minister of Tax – we expect this will enter into force for the income year 2024.

Why is this great news?

This is great news for Danish companies operating in France, as the new agreement will provide clarity on the taxation of pensions and help to reduce compliance costs. Here are five good reasons why Danish companies should consider the content of the double taxation agreement when sending employees to work in France.

How can we assist you?

Are you a Danish company who are operating or wants to operate business in France? Let us help you navigate the new tax laws and requirements.

What we will do for you:

1. First, we will inform you in your specific situation. We have a extensive knowledge which can help understand the details of the new agreement, including the provisions related to pensions and other benefits.

2. We will then make sure that you are following all requirements related to compliance, reporting, and withholding.

3. On top of that we will ensure that the payroll reports are handled correctly for your employees working in France, including any relevant tax withholding requirements.

What you will get out of it:

1. Avoiding costly penalties or other legal issues that could arise from non-compliance.

2. Ensuring that employees receive the proper compensation and benefits they are entitled.

3. Minimizing your overall tax burden.


In conclusion, the new double tax treaty between Denmark and France addresses the taxation issues faced by Danish pensioners and businesses operating in France. The agreement ensures that Denmark can tax pension payments to individuals residing in France, while also granting relief for the tax paid in France. For Danish businesses operating in France, the agreement provides certainty and stability in terms of taxation, ensuring compliance and avoiding potential disputes.

United Tax Network - Denmark is now Crossbord

The world is changing and so are we.

Our services are not limited to international tax, so we have changed our name to Crossbord, which better reflects all of how we can help you: 

We are your partner in all your global mobility situations where you cross the border in or out of Denmark.