What is the Danish tax authority's "positive list"?
The "positive list" (positivlisten) is the everyday name for the Danish Tax Agency's list of equity-based investment companies. If an ETF or foreign fund is on the list, a Danish investor's gain is taxed as share income (27 % / 42 % in 2026) on a mark-to-market basis, and the fund may be held in an aktiesparekonto. If it is not on the list, the gain is taxed as capital income — usually at a higher rate — and it does not belong in the aktiesparekonto.
Why the list exists
Most ETFs are foreign funds, and Danish tax law calls them investment companies. The main rule is that gains on them are capital income. The exception is funds where on average at least half of the assets are shares, and which have registered with the Danish Tax Agency as equity-based. Those funds make up the list.
A fund must register by 1 November of the year before the status applies. So it is the fund provider that has to act — not you. A perfectly good fund can be missing from the list simply because its provider never applied.
The difference in money
Made-up example: your ETF rises DKK 10,000 in a year, and you are below the progression threshold for share income.
- On the list: share income, 27 % = DKK 2,700.
- Not on the list: capital income. The tax depends on your other income but is typically around 37–42 % = about DKK 3,700–4,200.
Same fund, same return, up to DKK 1,500 more tax — every year, because both are taxed on a mark-to-market basis. And if it goes the other way, a loss as capital income is worth less as a deduction.
How to check a fund
- Find the fund's ISIN — a 12-character code that often starts with IE, LU or DE. It is shown by your bank or broker and in the fund's factsheet.
- Go to skat.dk and open the "Liste over aktiebaserede investeringsselskaber" for the current year.
- Search for the ISIN. If it is there, the fund is equity-based for that year.
Many brokers and websites also show the status, but the Tax Agency's list is the final word. It applies one income year at a time — check again when the year changes.
Your Danish investment fund is not on the list? That is normal
The positive list only covers investment companies — typically foreign ETFs and funds. A Danish distributing investment fund (udloddende investeringsforening) is a different thing in Danish tax law, and it never appears on the list. The name often gives it away: a “d” or “udb” means distributing, for example “Danske Invest USA Indeks KL DKK d”.
If the distributing fund is equity-based, this is what applies to a Danish investor in 2026:
- Dividends are taxed every year as share income (27 % / 42 %).
- Gains are taxed only when you sell — realisation basis using the average-cost method, also as share income. Not every year, as with an ETF on the list.
- Losses can only be offset against gains and dividends on shares and fund units traded on a regulated market.
- It may be held in an aktiesparekonto.
Watch out for Danish accumulating funds (“akk”): they are usually investment companies, just like ETFs, so you do need to look them up on the list. An ISIN starting with DK does not settle the question on its own.
The aktiesparekonto
An aktiesparekonto may hold listed shares, equity-based investment companies that are on the Tax Agency’s list, and units in Danish equity-based funds with minimum taxation (the distributing ones). The deposit cap is DKK 174,200 in 2026, and returns are taxed at 17 %. A foreign ETF that is not on the list cannot be used to fill the account.
The typical beginner's mistake
Picking a theme ETF because it rose the most, and only afterwards discovering it is not on the list. Then the gain is capital income every year — and it cannot be moved into the aktiesparekonto.
How you see it in Kiggo
For every ETF, Kiggo shows a checklist with TER, accumulating or distributing, size and replication. Kiggo does not look up the tax status for you — the list changes every year, and the Danish Tax Agency has the final word. Use the fund's ISIN on skat.dk.
Related terms
Frequently asked questions
What if my ETF is not on the list?
For a Danish investor, the gain is taxed as capital income on a mark-to-market basis — tax on each year's rise, usually at a higher rate than share income. And the fund may not be held in an aktiesparekonto.
When is the list updated?
Funds must register by 1 November of the year before, and the list applies for a whole income year. The Tax Agency updates it during the year, so check the current list for the year you buy in.
Can a fund drop off the list?
Yes. The fund must report each year how its assets are split, and on average at least 50 % must be shares. If the report is missing or the share portion falls, it loses the status.
My Danish investment fund is not on the positive list — is that a problem?
No, not if it is distributing. The positive list only covers investment companies. A Danish distributing equity fund is taxed as share income: dividends every year and the gain only when you sell. It may also be held in an aktiesparekonto. If the fund is accumulating, it is usually an investment company — then look it up on the list.
Kiggo explains — Kiggo does not advise. We never tell you what to buy or sell, and key figures can only be compared between companies in the same industry. The decision is yours. Last updated 2026-09-25.
Written by Claus Frisch, founder of Kiggo. Not an adviser, not a bank — Kiggo explains, you decide.
