Denmark has no double tax treaty with the UAE. The Danish Tax Agency said so in a binding answer of August 2026 about a Dane working in Abu Dhabi. So Danish tax depends only on Danish law. If you keep a year-round home available in Denmark, you stay fully liable to Danish tax on your worldwide income, however long you live in Dubai. Your UAE salary can still be fully relieved under section 33 A of the Tax Assessment Act, but only if three things hold: you stay abroad for at least six months, you spend no more than 42 days in Denmark in any six-month period, and the move is tied to your job rather than your own choice to live abroad. The section does not require the UAE to tax the salary.
This guide is for Danish citizens and Danish residents who live and work in the UAE. It covers when full Danish tax liability ends, section 33 A and the 42-day rule, the August 2026 ruling on returning home during the regional security situation, exit tax on shares and crypto, and the order to deal with it all.
The UAE side is simple. The UAE does not tax employment income, as our guide to what a tax-free salary really means explains, so every question here is about Denmark.
No Treaty, So Danish Law Decides Everything
In binding answer SKM2026.370.SR, published in August 2026, the Danish Tax Agency (Skattestyrelsen) stated that Denmark has not concluded a double tax treaty with the UAE. It added that, as a result, there can be no treaty relief and no move of tax residence under a treaty. The person in that case kept a home in Denmark, so Denmark could tax him on all his income, wherever it came from.
That has three consequences for a Dane in Dubai:
- There is no tie-breaker. Living in Dubai with your family does not override Danish liability if you still have a home available in Denmark.
- A UAE tax residency certificate does not end Danish liability. It is still useful evidence of where you live and work.
- Section 33 A is the only relief for UAE salary. The skat.dk page for residents working abroad confirms that if there is no treaty with the work country, section 33 A gives full relief when its conditions are met.
When Full Danish Tax Liability Ends
Under section 1 of the Withholding Tax Act (kildeskatteloven), two groups are fully liable to Danish tax: people with a home (bopæl) in Denmark, and people without a home who stay in Denmark for at least six months, counting short trips abroad for holidays. The Agency’s binding answer describes the practice: having a year-round dwelling available in Denmark is, as a starting point, both a necessary and a sufficient condition for having a home there.
The skat.dk page on moving from Denmark says full liability normally ends only when you do one of these:
| What you do with your Danish home | Effect |
|---|---|
| Sell it | Full liability can end |
| End your lease | Full liability can end |
| Rent it out for at least three years, on a lease you cannot terminate | Full liability can end |
| Keep it, or rent it out on terms you can end within three years | You stay fully liable |
| Keep only a summer house used for holidays | Normally not treated as a home |
The page on working abroad adds that you have a home in Denmark if you own or rent a year-round dwelling there, live permanently with your parents or partner there, or regularly stay overnight in Denmark for work, weekends or holidays.
Skattestyrelsen asks people who move abroad to call it on 72 22 28 92 once a week has passed since they deregistered from the Civil Registration System (CPR) and physically left Denmark. Only then will it decide on your tax liability.
Section 33 A: Relief for Your UAE Salary While You Are Still Liable
Section 33 A of the Tax Assessment Act (ligningsloven) reduces your total Danish income tax by the part that falls on foreign salary. The Legal Guidance, section C.F.4.2.1 (2026-2 edition), lists the conditions:
| Condition | What it means in the UAE |
|---|---|
| You are fully liable under section 1 of the Withholding Tax Act | Usually because you kept a home in Denmark |
| You stay outside the realm for at least six months | Greenland and the Faroe Islands count as inside the realm |
| The stay abroad is caused by the employment | A UAE job with a UAE employer qualifies. Moving to Dubai by your own choice while keeping a Danish job does not (Eastern High Court, SKM2023.18.ØLR). |
| Stays in Denmark total no more than 42 days in any six-month period, and are only for necessary work linked to the stay abroad, or for holidays and similar | You must be able to document every day. A pilot lost the relief because he could not prove that one flight avoided Danish airspace (SKM2026.158.VLR). |
| The income is salary for personal work as an employee | Freelance fees do not qualify |
Section 33 A itself contains no condition that the salary is taxed in the work country. The citizen page on skat.dk lists “you are liable to tax abroad” among the conditions, but the statute and the Legal Guidance do not. In SKM2026.370.SR the Tax Council confirmed that salary from an Abu Dhabi employer was covered by section 33 A, as long as the conditions were met.
Because there is no treaty, relief under section 33 A for UAE salary is full relief. The half relief in section 33 A(3) applies only where a treaty gives Denmark the taxing right.
The digital nomad trap
The Eastern High Court held in SKM2023.18.ØLR that section 33 A does not apply when an employee who keeps full Danish liability chooses, on their own and independently of the employer, to live abroad in a country with no link to the employer’s business. If you move to Dubai and keep working remotely for your Danish employer while keeping your Danish home, expect your salary to be fully taxed in Denmark.
The 42-Day Rule When You Have to Come Home
SKM2026.370.SR involved a Dane and his spouse who had lived in Abu Dhabi since 2023 and kept an owned home in Denmark that was not let on a non-terminable three-year lease. He worked for an Abu Dhabi employer from September 2023 until January 2026. In March 2026 the couple returned to Denmark temporarily because of the security situation in the region and the Ministry of Foreign Affairs’ advice against staying in the UAE. He asked for a dispensation from the 42-day rule.
The Tax Council’s answer:
- No dispensation. A stay in Denmark beyond 42 days will, as a starting point, break access to section 33 A. No special rule has been introduced, unlike the temporary COVID-19 rule in section 33 A(6), which covered only 9 March to 30 June 2020.
- Salary already earned stays relieved. His Abu Dhabi salary up to the end of his employment in January 2026 was covered by section 33 A, provided the conditions were met.
- A third country is an option. The Agency noted that a temporary stay outside the UAE does not have to be in Denmark. A stay in another country can be compatible with section 33 A, as long as it is in the nature of a holiday or similar.
If you have to leave the UAE at short notice, count your Danish days before you book a long stay at home.
Exit Tax on Shares and Crypto
When full liability ends, the skat.dk moving page says:
- Shares worth DKK 100,000 or more are treated as sold on the day you move, so you are taxed on the unrealized gain. You can apply for a deferral (henstand) until the gain is realized.
- Crypto holdings are treated as sold at market value on the day you move, so you can owe tax on a gain you have not received.
- Pension return tax (pensionsafkastskat) no longer applies to returns on your Danish pension savings once full liability ends. Apply for exemption on form 07.058 and send the certificate to your bank or pension company. If you return, you must tell the Agency, your bank and your pension company, or you can be fined.
When your Danish pension is paid out, skat.dk says the treaty between Denmark and your country of residence decides where it is taxed. With no Denmark to UAE treaty, nothing limits Denmark’s right to tax a Danish pension.
The Order to Do This In
- Decide what happens to your Danish home. Sell it, end the lease, or rent it out on a lease you cannot terminate for at least three years. Anything else keeps you fully liable.
- If you keep the home, make sure section 33 A applies. The UAE stay must be caused by a UAE job, and your Danish days must stay at 42 or fewer in any six-month period.
- Keep evidence of every day: boarding passes, a travel log and UAE entry and exit records. Our guide to the UAE entry and exit report shows how to get them.
- Report UAE salary in TastSelv under foreign income (box 15) and state that you use section 33 A. A Danish employer can apply on form 01.016 to stop withholding.
- Before you deregister, value your shares and crypto and decide whether to apply for deferral of the share exit tax.
- Apply for exemption from pension return tax on form 07.058 once full liability ends.
- Call Skattestyrelsen a week after you have deregistered and left.
A UAE certificate is still useful evidence of where you live; see our UAE tax residency certificate guide. UAE banks report Danish account holders under CRS; see how UAE banks report accounts under CRS. Sweden and Norway also have no income tax treaty with the UAE; compare our guides for Swedes in the UAE and Norwegians in the UAE.
What We Could Not Verify
- The statute text on Retsinformation. retsinformation.dk blocked every request we made, so the section 1 and section 33 A wording here comes from the Agency’s own quotations in the Legal Guidance and in SKM2026.370.SR.
- Why skat.dk’s citizen page lists foreign tax liability as a condition of section 33 A, when the statute and the Legal Guidance do not. If you rely on section 33 A for a UAE salary, keep SKM2026.370.SR on file.
- The current rules on crypto exit tax and share exit tax deferral, including any security required. Read the linked skat.dk pages for the year you move.
Frequently Asked Questions
Is there a tax treaty between Denmark and the UAE?
No. The Danish Tax Agency confirmed in binding answer SKM2026.370.SR, published in August 2026, that Denmark has not concluded a double tax treaty with the UAE.
Do I stay Danish tax resident if I keep my house?
Yes. Having a year-round dwelling available in Denmark normally means you have a home there and remain fully liable on worldwide income. Liability normally ends only if you sell the home, end your lease, or rent it out for at least three years on a lease you cannot terminate.
Is my UAE salary taxed in Denmark?
Not if you are no longer fully liable. If you are, section 33 A of the Tax Assessment Act gives full relief on UAE salary when you stay abroad at least six months because of your job and spend no more than 42 days in Denmark in any six-month period.
Does section 33 A require the UAE to tax my salary?
The statute does not. In SKM2026.370.SR the Tax Council confirmed that salary from an Abu Dhabi employer was covered by section 33 A if its conditions were met, even though the UAE does not tax salaries.
Can I use section 33 A if I work remotely for a Danish employer from Dubai?
Usually not. The Eastern High Court held in SKM2023.18.ØLR that section 33 A does not apply when an employee chooses on their own to live abroad, independently of the employer, in a country with no link to the employer’s business.
Can the 42-day rule be waived if I have to leave the UAE for safety reasons?
No. In SKM2026.370.SR the Tax Council refused a dispensation for a Dane who returned from Abu Dhabi in March 2026. No special rule like the COVID-19 rule was introduced. Spending the time in a third country, as a holiday, may be compatible with section 33 A.
Is there exit tax when I move from Denmark to Dubai?
Yes, if your shares are worth DKK 100,000 or more, they are treated as sold on the day you move, with an option to defer payment. Crypto holdings are treated as sold at market value on the day you move.
Do I still pay pension return tax after moving?
Not once full Danish liability has ended. Apply for exemption on form 07.058 and send the certificate to your bank or pension company.
Official Sources
- Skatterådet, binding answer SKM2026.370.SR: the 42-day rule in section 33 A during unrest in the work country (UAE), August 2026 (Danish)
- Den juridiske vejledning 2026-2, C.F.4.2.1 Tax relief under section 33 A(1) of the Tax Assessment Act (Danish)
- Den juridiske vejledning 2026-2, C.F.4.2 Section 33 A of the Tax Assessment Act (Danish)
- Skattestyrelsen, Du flytter fra Danmark (moving from Denmark) (Danish)
- Skattestyrelsen, Du bor i Danmark og arbejder i udlandet (living in Denmark and working abroad) (Danish)
Information current as of October 2026. Verify with official authorities before proceeding.
This guide is for informational purposes only and is not tax advice. Danish and UAE regulations are subject to change. Always verify current requirements with the relevant official authority, or a licensed tax adviser, before proceeding with any filing or transaction.
