Globe-Trotting Sportsman Or Entertainer: Denmark

An Danish citizen with extensive, international, multi-sourced income is not in a good tax situation unless he or she can establish non-residence, since full, world-wide taxation of income and capital gains will apply.

If resident in Denmark, the peripatetic professional may well find himself paying withholding tax in a number of countries which cannot in some cases be reclaimed or set off against Italian taxation because of the absence of a tax treaty.

Such an individual will almost certainly resort to corporate structures to market his or her skills and manage derivative income flows. Complex structures may be necessary if the anti-avoidance rules are to be avoided.

Apart from the extra difficulty of minimising tax on the income side, an Danish-resident sportsman or entertainer will be in the same position as any other Danish resident. (Select 'High-Tax Country Resident' and 'Denmark' for a fuller description).

In order to lose tax residence it is first necessary to stop fulfilling residence criteria in a given tax year.

Foreign sportsmen and entertainers' earnings in Denmark may be subject to withholding tax at a rate between 20% and 30%; but this rule is not always enforced, and double tax treaties will often apply.

If a foreign sportsman or entertainer becomes a Danish resident, then he or she is in the same position as an expatriate executive (select 'Expatriate Executive' and 'Denmark').

www.lowtax.net contains details of the offshore business sectors of 50 jurisdictions, and their taxation.

NB: The suggestions given above do not constitute investment advice. They are intended only to assist individuals in finding appropriate professional advice, which is essential for anyone planning offshore investment.