Leave Denmark for Cyprus, with the exit planned.

Yes, if your shares are worth DKK 100,000 or more and Denmark taxed your share gains for at least seven of the last ten years. When you stop being fully taxable in Denmark, your shares are treated as sold at market value and the gain is taxed at 27% and 42%. You can defer it with no interest and, for a move to Cyprus, no security.

No. That rule is for business assets, not shares. The deferred tax on your shares has no end date. It falls due only when certain things happen, such as a sale, a dividend or a loan from a company on your list, or a missed yearly form.

When you no longer have a home in Denmark at your disposal. It's about where you actually live, not your registered address. A year-round home you keep, even just in case, keeps you fully taxable, and the exit tax isn't triggered either. A summer house usually doesn't count unless someone lives in it all year.

Often, as long as no single stay reaches six months. Without a home in Denmark, a stay of six months makes you fully taxable again, counted from its first day. Holiday trips abroad don't break the stay, so a long Danish summer with two weeks in Cyprus in the middle counts as one stay.

You can, but it costs you. Dividends it pays you in Cyprus lose 15% to Danish withholding tax under the treaty. Because the ApS is on your list of shares, each dividend also makes part of your deferred exit tax due. And a Danish company that owns your Cyprus company runs into Denmark's rules on foreign profit. The set-up that works is holding the Cyprus company personally.

It can if a Danish company owns it, whatever Cyprus's tax rate. Denmark's rules that tax a foreign company's profit at home catch a company controlled more than 50% from Denmark once over a third of its income is the kind they target, such as interest and royalties. Once you've left Denmark and own the Cyprus company yourself, there's no Danish parent for the rules to reach.

Your Danish state pension can be paid in Cyprus. The base rule is 30 years living in Denmark before you retire, and short of a full record you get a part pension rather than nothing. Supplements such as the heating supplement aren't paid abroad automatically, so you apply to Udbetaling Danmark after you move. Your ATP pension is paid wherever you live, once ATP knows about the move.

No. Under the 60-day rule you can be Cyprus tax resident with 60 days a year here, a home you rent or own, a business or job in Cyprus, and no more than 183 days in any other country. Since 2026 it works even while Denmark still treats you as resident. Running your own Cyprus company can count as the business.

Yes. It has applied since 2012 and was updated in 2021. Dividends from a Danish company to you are taxed at 15% at most, and interest and royalties carry no withholding tax. Growth in your shares after you move is taxed where you live. The treaty doesn't undo the exit tax, which covers the growth before you left.