PAL-exemption deadlines stated: 1 May normally, 31 December for Germany treaty

Individuals who are no longer fully tax-liable or tax-resident in Denmark but hold Danish or approved foreign pension schemes can apply for exemption from Danish pension-returns tax (PAL-skat) on form 07.058, and the tax administration's guidance now states the application deadlines. The ordinary deadline expires on 1 May in the fourth year after the end of the income yearSkat, under section 26(2) of the Tax Administration Act — three years and four months after the income year ends. Applicants who miss it may seek extraordinary reopening only on one of the exhaustive special grounds in section 27Retsinformation.

Before applying, the applicant's Danish tax liability must be settled: the guidance advises calling the tax administration or filing form 04.029 on the move from Denmark. Residents of Sweden with a Danish pension scheme cannot be exempted after 1 January 2025Skat, and residents of Greenland with a Danish scheme cannot be exempted at allSkat.

Persons covered by the Denmark-Germany double-taxation treaty get a longer route. Where Germany holds the taxing right to the pension return under article 21(1) of the treatyRetsinformation and the person was tax-resident in Germany when the return was earned and creditedRetsinformation, the refund deadline is four years after the end of the calendar year in which the return was earned and credited, under article 46(3) — i.e. 31 December in the fourth year after the income year. Denmark may still withhold PAL-tax at source under article 46(1), but the withheld tax is then refunded under article 46(2). The administration's 2025 steering signal changed practice from the section 26(2) deadline to the treaty deadline as the longest and most favourable time limit for these applicantsRetsinformation: a return earned and credited in 2021 must be reclaimed by 31 December 2025. Cases previously refused within the treaty window are reopened on the administration's own initiativeRetsinformation.

The ordinary deadline and the treaty deadline run side by side: a German-resident applicant files under the treaty windowSkat, everyone else under section 26(2)Skat, with section 27 as the only fallback. Further detail sits in the Legal Guide, section C.G.1.1.1.

Legal basis: Skat.dk guidance on form 07.058 (Ansøgning, Fritagelse for at indeholde og indbetale pensionsafkastskat); section 26(2) and section 27 of the Tax Administration Act (skatteforvaltningsloven); articles 21(1) and 46(1)-(3) of the Denmark-Germany double-taxation treaty; Skattestyrelsen steering signal of 2025 on PAL-tax refunds under the German treaty.