France tax treaty Denmark : your property in France

Yes. The former 1957 treaty ended on 1 January 2009, after Denmark terminated it. A new treaty signed on 4 February 2022 has been in force since 29 December 2023 and has applied since 1 January 2024.

In both countries. France taxes the rental income (article 6). Denmark also taxes it and deducts the French tax, within the limit of its own tax on that rental income (article 22 § 1).

No. It is taxable in France without being taxable only there. Denmark therefore applies the tax credit and the exemption of article 22 § 1 c does not apply.

Yes if you occupy it or keep it at your disposal. It is not due for the time the property is let. You also escape it if you have been a Danish tax resident since 28 November 2007 and bought before 29 November 2007.

Yes. Skattestyrelsen accepts the property tax on built properties and the housing tax for the part you occupy yourself, within the limit of the Danish tax. You must declare these amounts yourself.

Yes, unless the sale is exempt under Danish law: a home you occupied, a plot of less than 1,400 m². Otherwise, the gain is capital income and the French tax is deducted within the limit of the Danish tax.

Not without a prior calculation. The SCI removes the €150,000 exemption on resale in France. The Danish authority in principle treats it as transparent, which leaves the Danish tax on the value of the home with the partners. The anti-abuse clause of article 29 also covers arrangements whose tax advantage is one of the principal purposes. Have the structure validated by a Danish adviser before signing.

No. Denmark is an EU member and is linked to France by the required assistance agreements.

Yes if the net value of your French properties exceeds €1.3M on 1 January. The 2022 treaty does not deal with wealth: only French law applies.

7.5% if you are affiliated to Danish social security and dependent on no French scheme. Remember to tick box 8SH or 8SI. Otherwise, 17.2% on unfurnished rental and on the capital gain, 18.6% on furnished.

No treaty prevents it, but Danish law deducts the duties paid in France on this property, within the limit of the Danish duties on it (§ 15 of the boafgiftsloven). In practice you bear the higher of the two.

By no treaty. France taxes the property (article 750 ter of the CGI). Danish law provides a deduction for tax paid abroad on assets located there (§ 29 of the boafgiftsloven). Have the transaction checked by a notary and a Danish adviser before signing.