When a Danish Influencer Moves Abroad: What Happens to Danish Tax Liability on Brand Deals

Why moving abroad isn't enough on its own

Many influencers assume Danish tax liability automatically ends the day they move abroad — that the move itself is what counts. It isn't. Denmark's source tax act (kildeskatteloven) doesn't test where you currently live; it tests whether you have given up your Danish residence (bopæl). That's a legal test, not a geographic one, and it can catch out a creator who relocates to Lisbon or Berlin but keeps their Copenhagen apartment "just in case".

The rule that actually decides it: residence, not days abroad

Full Danish tax liability follows from kildeskatteloven § 1, stk. 1, nr. 1: the duty to pay Danish income tax rests on "personer, der har bopæl her i landet" ("persons who have residence in this country"). Skattestyrelsen's own legal guide is explicit about what that means on relocation: "Om skattepligten ophører ved fraflytning afgøres ud fra, om den skattepligtige har bevaret bopæl her i landet" — whether tax liability ends on moving abroad is decided by whether the taxpayer has retained residence here (info.skat.dk, section C.F.1.2.3). In practice, what matters is whether you still have disposal of a year-round home in Denmark — not how many days a year you actually spend there, and not how long you plan to stay abroad.

That means an influencer who moves to Portugal and lives there 300 days a year can still be fully tax liable to Denmark on their entire worldwide income — including brand deals with foreign companies, agreed and delivered entirely from Portugal — if their Danish apartment is simply left empty or rented out short-term.

How you actually give up Danish residence

Per Skattestyrelsen's guidance, there are two real routes to giving up residence, and only two:

• Sell the home. The most unambiguous route — you simply no longer own or lease a Danish year-round residence.
• Rent it out non-cancellably for at least 3 years. As Skattestyrelsen itself puts it: "I praksis kan en person — i stedet for en endelig afhændelse af boligen — vælge at udleje/fremleje boligen uopsigeligt i mindst 3 år" — in practice, instead of a final disposal of the home, a person can choose to let it non-cancellably for at least 3 years (info.skat.dk, C.F.1.2.3). The lease has to be genuinely non-cancellable by you for the full period — an arrangement you could end early yourself doesn't count.

Simply leaving isn't enough. A short-term or cancellable rental generally preserves your residence, and with it your full tax liability, unless there is "very clear" evidence the move is permanent — and the burden of proof sits with you, not with Skattestyrelsen. A summer cottage used only for holidays generally doesn't count as a year-round home that maintains residence, unless there are other strong ties to Denmark.

What full tax liability means for your brand deals while you still have residence

As long as you remain fully tax liable to Denmark, you're taxed on your worldwide income — not only what you earn in Denmark. That includes income from brand deals, affiliate commission and platform payouts, regardless of whether the foreign brand you work with even knows you live abroad, and regardless of whether the payment ever touches a Danish bank account. How the income itself is classified — fee recipient, hobby business or self-employed, as covered in employee or self-employed? — doesn't change because you've relocated. What changes is whether Denmark has any right to tax it at all.

Once liability is limited: what Denmark can still tax

Once residence has genuinely been given up — sold, or let non-cancellably for at least 3 years — full tax liability ends, and you move instead to limited tax liability under kildeskatteloven § 2. Limited tax liability covers only specific, enumerated categories of Danish-source income — not any income a Danish citizen happens to earn anywhere in the world. The categories relevant to a creator include: income from Danish real property, income from a business with a fixed place of business (permanent establishment) in Denmark, and — a nuance worth knowing — fees for contract work so closely integrated into a Danish company's own operations that it functions in substance like employment.

Ordinary fee income for work performed entirely abroad is not one of the enumerated categories. A brand deal with a foreign (or, for that matter, Danish) company, where you film, edit and post the content from your new home abroad, generally falls outside Danish taxation once residence has been given up — regardless of the brand's own nationality. That's an important, often-missed point: it isn't the brand's nationality that decides it, it's where the work is actually performed, and whether you've given up your Danish residence.

Double taxation: when two countries both think they can tax you

Denmark no longer treating you as fully tax liable doesn't automatically mean your new country of residence agrees, or that no overlap arises during the transition. Denmark has double tax treaties (dobbeltbeskatningsoverenskomster) with a large number of countries, and most follow the same underlying logic as the OECD Model Tax Convention: where both countries would otherwise treat you as tax-resident at the same time, a "tie-breaker" test decides it — typically in the order of a permanent home available, center of vital interests, habitual abode, and finally nationality. The specific treaty between Denmark and your new country governs the exact rules, and that isn't something this article can settle in general terms — it's a question for an accountant with international tax experience, particularly during the period residence is actually being given up.

Decision framework

• IF you move abroad but keep your Danish home without selling it or letting it non-cancellably for at least 3 years THEN you remain fully tax liable to Denmark on your entire worldwide income, regardless of where you actually live and work from.
• IF you sell the home, or sign a genuinely non-cancellable 3-year lease THEN full tax liability ends from that point, and only specific Danish-source income categories remain taxable afterward.
• IF you keep working in a closely integrated role with a Danish brand or agency after the move — one that looks more like employment than an independent deliverable THEN it's worth getting separately confirmed whether that could trigger limited tax liability as "contract work integrated into a Danish enterprise".
• IF you're unsure whether a shorter or cancellable rental is enough THEN assume it isn't — the burden of proving residence has genuinely been given up sits with you.
• IF your new country of residence also wants to tax the same income THEN it's the specific double tax treaty between Denmark and that country that decides who actually has the taxing right — get it confirmed by an accountant, not assumed.

Worked example (hypothetical)

The figures below are made up to illustrate the mechanism only — not a real customer case, and not a calculation of actual tax owed.

An influencer with residence in Copenhagen earns DKK 480,000 a year: DKK 60,000 from a single campaign for a Danish agency, and DKK 420,000 from a series of brand deals with foreign companies. On 1 March, she moves to Spain.

• Scenario A — she keeps her Copenhagen apartment, without selling it or letting it non-cancellably for 3 years. Her residence hasn't been given up, and all DKK 480,000 — both the Danish campaign and the foreign brand deals — remains subject to full Danish tax liability for the rest of the year, exactly as if she'd never moved.
• Scenario B — she sells the apartment on 1 March, the same day she moves. Full tax liability ends from that date. The Danish campaign (DKK 60,000, completed before the move) was already taxed as usual. The DKK 420,000 from foreign brand deals, performed after 1 March from her new home in Spain, doesn't fall under any of the enumerated § 2 categories and generally falls outside Danish taxation as a result — it's instead Spain's own rules (and any Denmark-Spain double tax treaty) that decide what she owes there.

The difference between the two scenarios comes down entirely to whether the home was genuinely disposed of — not to how much time she actually spent in Denmark or Spain that year.

Common mistakes

• Assuming the move itself is enough. It's residence, not location, that decides it.
• Keeping the apartment "just in case" and assuming there's no consequence. That's exactly what extends full tax liability.
• Renting the home out short-term or with a break clause and assuming it counts as giving up residence. It generally doesn't — the lease has to be genuinely non-cancellable for at least 3 years.
• Assuming a foreign brand automatically means no Danish tax. It isn't the brand's nationality that decides it, it's whether you've given up your own Danish residence.
• Forgetting the new country's own rules and any applicable double tax treaty. Escaping Danish tax liability doesn't automatically settle what you owe in your new country.

Make Influence's perspective

Make Influence doesn't advise on an individual creator's tax situation — that's a question between the creator and their own accountant, particularly in a relocation scenario where the consequences can run for years. What we see in practice is that "moving abroad" tends to get treated as a lifestyle decision with no administrative consequence, while the housing step — selling, or letting non-cancellably for 3 years — gets overlooked or postponed. That's exactly the detail that decides whether a whole year of brand income stays Danish-taxable or not.

FAQ

Does my Danish tax liability end automatically when I move abroad?

No. It only ends once you've genuinely given up your Danish residence — either by selling the home or by letting it non-cancellably for at least 3 years. The move itself isn't enough on its own.

Does it count if I rent my apartment out for a year or two?

Generally not. The rental has to be non-cancellable on your side for at least 3 years for it to count as genuinely giving up residence.

Do I owe Danish tax on brand deals with foreign companies if I still have residence in Denmark?

Yes. As long as you're fully tax liable, your worldwide income is taxed in Denmark — including foreign brand deals, regardless of where the work was performed.

What happens to income from Danish brands once I've moved and given up residence?

It generally falls outside Danish taxation the same way foreign brand deals do — it isn't the brand's nationality that decides it, it's where the work was performed and whether you've given up residence. An exception can apply if the work is so integrated into the Danish company's own operations that it resembles employment.

What if both Denmark and my new country want to tax the same income?

That's a double taxation situation, resolved by the specific double tax treaty between Denmark and that country. Get it confirmed by an accountant with international tax experience.

Does this work the same way if I run my influencer business through a sole proprietorship or an ApS?

The business structure decides how the income is classified and taxed while you remain tax liable to Denmark — see ApS or enkeltmandsvirksomhed. The relocation question in this article applies regardless of business structure, but an ApS raises its own, separate questions about the company's own tax residence, which are outside the scope of this article.

Do I still need to update my forskudsopgørelse while I'm in the process of moving?

Yes — as long as you remain fully tax liable, your expected income still needs to be accurate in TastSelv. See the forskudsopgørelse for influencers for which field to correct and how to avoid restskat.

Do the same VAT rules apply once I've moved?

VAT is a separate question from the income-tax liability covered in this article — see affiliate influencer marketing in Denmark for how the DKK 50,000 Danish VAT threshold works, and confirm your own situation with an accountant if you keep a Danish CVR registration after moving.

Do gifted products I receive after moving still count as income?

Yes, if the product is payment for a deliverable — but whether Denmark or your new country has the right to tax it is decided by the same residence-and-source principle as the rest of this article. See Skattestyrelsen's 2026 crackdown on gifted products for the gift-vs-payment distinction itself.

How does this relate to how I actually get paid by foreign brands?

That's a separate, practical question from the tax liability itself — see how to pay international influencers (written from the brand's side, but useful for understanding what's expected of your invoice) for currency, invoicing requirements and VAT on cross-border payments.