Category: Tax comparisons

When moving between the UK and Denmark, it is important to be aware of the differences that each jurisdiction imposes on areas of personal taxation. Failing to comply with the relevant procedures and local tax legislation could leave individuals with a series of penalties.

The table below highlights a list of arguably the most important areas of personal taxation that individuals should be aware of when moving between the UK and Denmark. Whilst both countries tax residents on their worldwide income, this is where similarities cease as from here on, the UK and Danish tax systems function differently in almost every way.

UK Tax System vs Danish Tax System:


UK Tax System Danish Tax System
Tax Year for individuals 6 April to 5 April 1 January to 31 December
Who is required to file a Tax Return In the UK, most individuals who are employed will pay tax on their income through payroll and are not required to file a Tax Return.

Tax Returns are required where:

  • Earnings are over £100,000 in a tax year
  • In receipt of non-UK sourced income
  • In receipt of property income
  • In receipt of taxable savings, investments and dividends
  • Claiming income tax reliefs
  • Need to pay capital gains tax
  • Self-employed or partnership income
  • Liable to high income child benefit charge
  • In receipt of taxable income which has not yet been taxed

In Denmark, most individuals who are employed and pay tax on their income through payroll are not required to file.
Tax Returns are required where:

  • In receipt of non-Danish source income
  • In receipt of property income
  • In receipt of some taxable savings, investments and dividends
  • Income from self-employment
Payroll System In the UK, HMRC operates a Pay As You Earn (PAYE) system where tax is collected by the employer through every payslip. The employer then remits the tax withheld to the tax office (HMRC). In Denmark, if you are an employee, your tax is collected through every payslip and sent to the tax authorities. If you are not an employee, taxes are paid through monthly instalments by the individual.  
Tax Free Allowance UK residents (and in some instances non-residents) receive a tax-free personal allowance each year. In 2022-23, the tax-free personal allowance is £12,750. In certain circumstances this can be reduced or increased. The tax-free personal allowance in Denmark is DKK 46,600 for a full year.
Income Tax The UK operates progressive rates of income tax which include:
  • £0 to £12,570 (personal allowance) – 0%
  • £12,571 to £50,270 (Basic rate) – 20%
  • £50,271 to £150,000 (Higher rate) – 40%
  • Over £150,000 (Additional rate) – 45%
    		•  Denmark operates progressive rates of tax on personal income. The rates for 2022 are as follows:

    State tax:

    • Labour market (AM-bidrag)* 8%
    • Bottom tax rate 12.1%
    • Top tax rate 15% applies to income more than DKK 552,500 per year **

    Local tax rates:

    • Municipal tax rate (average) 24.983

    In Denmark there is however a tax ceiling, which is the maximum tax rate applicable to personal income. This ceiling is designed to ensure that the total income tax does not exceed 52.07% for personal income. Church tax and labour market contributions are not included in this tax ceiling.

    *Applicable on gross salary before tax
    **Pro rata
    Capital Gains Tax

    In the UK there is a Capital Gains Tax allowance of £12,300 per year (2022-23). After this your tax rate will depend on whether you’re a ‘Basic rate’ tax payer or ‘Higher rate’ tax payer:

    Basic Rate: 18% on residential property and 10% other chargeable assets

    Higher Rate: 28% on residential property and 20% other chargeable assets

    		 In Denmark, net positive capital gains income is taxed at 37% up to DKK 47,400 (DKK 94,800 for married couples) and 42% thereafter.
    Inheritance Tax In the UK, the standard Inheritance Tax threshold is £325,000 (which can increase to £500,000 where the home is passed to children of the deceased). Where an estate is valued over £325,000 there is a 40% Inheritance Tax rate. In Denmark, there is no Inheritance Tax on the first DKK 312,500 (2022). The inheritance tax for deceased´s children and descendants, stepchildren and their descendants, parents or cohabitants during the last two years of one´s life is 15%, for others the inheritance Tax is 25%.
    Tax Return Deadline 31 January following the end of the tax year (31 October if filing a paper return) 1 May following the end of the tax year. If you have foreign income or are self-employed it is 1 July.
    Tax Payment Deadline 31 January following the end of the tax year. This is the same as the tax return deadline. 31 December in the tax year if you want to avoid interest/surcharges. If you pay after 31 December but before the deadline 1 July 2022, you will avoid the surcharges and only pay the day-to-day interest of 1.7% from the 1 January till the payment date.
    Assessable on Worldwide Income UK residents, for tax purposes are taxed on their worldwide income*. Danish residents, for tax purposes are taxed on their worldwide income.
    National Insurance/ ATP In the UK, both the employee and employer are required to pay national insurance contributions each month. The rates vary from 0% to 13.8%. National Insurance is also due on self-employed income. In Denmark, both the employee and the employer are required to pay labour market supplementary pension (ATP).
    The employee part is DKK 94.65 per month and the employer part is DKK 189.30

    *Assessable on worldwide income (UK) – Individuals resident of the UK with non-domicile status can opt to claim remittance basis and not be taxed on their overseas income as long as it is not remitted to the UK.

    The UK and Danish Tax Systems: An Overall Comparison

    Determining which country has the more competitive tax system is relatively straightforward.

    Whether your income is subject to income tax or capital gains tax, it is evident from the table above, that the UK offers greater tax-free allowances and lower rates of tax. For example, the UK offers a capital gain allowance of £12,300 with a top rate of tax at 28% (residential property), whereas Denmark has no allowance and a 14% higher tax rate standing at 42%.

    As tax systems in the UK and Denmark are extremely different, it requires in-depth analysis to understand how each system operates and the implications which might then present for an individual on a case-by-case basis.

    Contact us

    If you require any advice or assistance with UK or Danish personal tax, we are here to help. Simply send us an email at the address below or fill in our contact form to arrange a free initial consultation.

    Denmark: John Munch, Tax Manager, Sheltons Accountants (Copenhagen), J.Munch@SheltonsGroup.com

    United Kingdom: Ned Shelton, Director, Sheltons Accountants UK (London), N.Shelton@SheltonsGroup.com

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    When moving between the UK and Singapore, it is important to be aware of the differences that each jurisdiction imposes on areas of personal taxation. Failing to comply with the relevant procedures and local tax legislation could leave individuals with a series of penalties.

    The table below highlights a list of arguably the most important areas of personal taxation that individuals should be aware of when moving between the UK and Singapore. Whilst both countries operate a progressive income tax system, this is where similarities cease as from here on, the UK and Singapore tax systems function differently in almost every way.

    UK Tax System vs Singapore Tax System:


    UK Tax System Singapore Tax System
    Tax Year for individuals 6 April to 5 April 1 January to 31 December
    Who is required to file a Tax Return In the UK, most individuals who are employed will pay tax on their income through payroll and are not required to file a Tax Return.

    Tax Returns are required where:

    • Earnings are over £100,000 in a tax year
    • In receipt of non-UK sourced income
    • In receipt of property income
    • In receipt of taxable savings, investments and dividends
    • Claiming income tax reliefs
    • Need to pay capital gains tax
    • Self-employed or partnership income
    • Liable to high income child benefit charge
    • In receipt of taxable income which has not yet been taxed

    Tax Returns are required where:

    • Individuals who are tax resident and have annual income of S$20,000 or more 
    • Non-resident individuals who derived income from Singapore 
    Payroll System In the UK, HMRC operates a Pay As You Earn (PAYE) system where tax is collected by the employer through every payslip. The employer then remits the tax withheld to the tax office (HMRC). In Singapore, there is no income tax withheld at source via payroll. It is the employee’s responsibility to file their annual tax declaration and pay directly to the Inland Revenue Authority of Singapore (IRAS), the local tax authority.
    Tax Free Allowance UK residents (and in some instances non-residents) receive a tax-free personal allowance each year. In 2023-23, the tax-free personal allowance is £12,750. In certain circumstances this can be reduced or increased. Tax residents of Singapore receive the first S$20,000 of their income charged at a 0% tax rate.
    Income Tax The UK operates progressive rates of income tax which include:
  • £0 to £12,570 (personal allowance) – 0%
  • £12,571 to £50,270 (Basic rate) – 20%
  • £50,271 to £150,000 (Higher rate) – 40%
  • Over £150,000 (Additional rate) – 45%
    		•  As with the UK, Singapore operates a progressive income tax system. The current individual tax rates in Singapore are as follows:
  • S$0 to S$20,000 – 0%
  • S$20,000 to S$30,000 – 2%
  • S$30,000 to S$40,000 – 3.5%
  • S$40,000 to S$80,000 – 7%
  • S$80,000 to S$120,000 – 11.5%
  • S$120,000 to S$160,000 – 15%
  • S$160,000 to S$200,000 – 18%
  • S$200,000 to S$240,000 – 19%
  • S$240,000 to S$280,000 – 19.5%
  • S$280,000 to S$320,000 – 20%
  • Above S$320,000 – 22%

    • The top marginal income tax rate will be increased with effect from Year of Assessment (YA) 2024 (calendar year 2023). Chargeable income in excess of $500,000 up to $1 million will be taxed at 23%, while that in excess of $1 million will be taxed at 24%; both up from the current rate of 22%.
    Capital Gains Tax

    In the UK there is a Capital Gains Tax allowance of £12,300 per year (2022-23). After this your tax rate will depend on whether you’re a ‘Basic rate’ tax payer or ‘Higher rate’ tax payer:

    Basic Rate: 18% on residential property and 10% other chargeable assets

    Higher Rate: 28% on residential property and 20% other chargeable assets

    		 Singapore has no capital gains tax.
    Inheritance Tax In the UK, the standard Inheritance Tax threshold is £325,000 (which can increase to £500,000 where the home is passed to children of the deceased). Where an estate is valued over £325,000 there is a 40% Inheritance Tax rate. Inheritance tax, also known as estate duty was abolished for deaths on and after 15 February 2008 in Singapore.
    Tax Return Deadline 31 January following the end of the tax year (31 October if filing a paper return) In Singapore, the filing due date for individual tax returns is 15 April following the end of the tax year. If filed electronically, the deadline is 18 April.
    Tax Payment Deadline 31 January following the end of the tax year. This is the same as the tax return deadline. Once your individual tax return has been filed, you will receive your Notice of Assessment or tax bill between May and September. Any tax liability is due in full within 30 days of receiving your Notice of Assessment.
    Assessable on Worldwide Income UK residents, for tax purposes are taxed on their worldwide income*. Overseas income received in Singapore is generally not taxable and need not be declared in the Income Tax Return (‘territoriality’ system) 
    National Insurance/ CPF In the UK, both the employee and employer are required to pay national insurance contributions each month. The rates vary from 0% to 13.8%. National Insurance is also due on self-employed income. Singapore operates ‘The Central Provident Fund’ (CPF). Both employees and employers must contribute to the fund. The statutory rate for employees is 20% and the rate of the employer’s contribution is 17%. (There are caps – above which CPF does not apply)

    *Assessable on worldwide income (UK) – Individuals resident of the UK with non-domicile status can opt to claim remittance basis and not be taxed on their overseas income as long as it is not remitted to the UK.

    The UK and Singapore Tax Systems: An Overall Comparison

    As you would expect, Singapore’s tax system is far more attractive than the United Kingdom’s.

    While the UK and Singapore both operate progressive income tax systems, the rate at which you pay tax in Singapore is substantially less, with the UK’s top rate of income tax over double that of Singapore’s. For example, where an individual earns a salary of £150,000 in the UK, they will pay a total of £52,460 in income tax. Whereas, if a tax resident earns £150,000 (S$250,500) in Singapore they will pay a total of £18,531 (S$30,947) in income tax. The above calculations are for illustrative purposes only, they do not consider any eligible reliefs or deductions in either country.

    Singapore’s tax system also boasts no tax on capital gains, where the UK, although offers a tax free allowance of £12,300, applies tax rates of between 10% to 28% on capital gains above this.

    What’s more, where Singapore has no inheritance tax, the UK still maintains an aggressive tax rate of 40% above the inheritance tax threshold.

    It is therefore evident that where an individual moves from the UK and acquires tax resident status in Singapore,  they can heavily reduce their tax burden.

    If you require any advice or assistance with UK or Singapore personal tax, we are here to help. Simply send us an email at the address below or fill in our contact form to arrange a free initial consultation.

    Contact us

    At Sheltons Accountants Singapore, Australai and the UK we have extensive experience in setting up and administering operations for overseas-based businesses. We provide a broad range of services, from setting up the entity and opening a bank account, to providing the legally required local director and a full range of tax, accounting, company secretarial and administrative services.

    We are also experienced in providing local and international tax advice, advice on tax treaty issues and cross-border tax efficient structures.

    If you need advice or assistance with UK, Singaporean or Australian matters, we’re here to help. Simply send us an email at SG@SheltonsGroup.com.

    Click here to read our blog where we compare the UK and Australian Tax systems.

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    When moving between the UK and Australia, it is important to be aware of the differences that each jurisdiction imposes on areas of personal taxation. Failing to comply with the relevant procedures and local tax legislation could leave individuals with a series of penalties.

    The table below highlights a list of arguably the most important areas of personal taxation that individuals should be aware of when moving between the UK and Australia. Whilst both countries operate a progressive income tax system, with the top tax rate peaking at 45%, this is where similarities cease as from here on, the UK and Australian tax systems function differently in almost every way.

    UK Tax System vs Australian Tax System:


    UK Tax System Australian Tax System
    Tax Year for individuals 6 April to 5 April 1 July to 30 June
    Who is required to file/lodge a Tax Return

    In the UK, most individuals who are employed will pay tax on their income through payroll and are not required to file a Tax Return.

    Tax Returns are required where:

    • Earnings are over £100,000 in a tax year
    • In receipt of non-UK sourced income
    • In receipt of property income
    • In receipt of taxable savings, investments and dividends
    • Claiming income tax reliefs
    • Need to pay capital gains tax
    • Self-employed or partnership income
    • Liable to high income child benefit charge
    • In receipt of taxable income which has not yet been taxed

    		 All Australian residents and non-residents with any Australian sourced income (some exclusions apply)
    Payroll System In the UK, HMRC operates a Pay As You Earn (PAYE) system where tax is collected by the employer through every payslip. The employer then remits the tax withheld to the tax office (HMRC). Australia operates a Pay As You Go Withholding system which deducts tax and is then paid to the tax office. As with the UK, the employer withholds tax when processing payroll and then forwards this to the tax office.
    Tax Free Allowance UK residents (and in some instances non-residents) receive a tax-free personal allowance each year. In 2023-23, the tax-free personal allowance is £12,750. In certain circumstances this can be reduced or increased. There is a tax-free threshold of $18,200 for all Australian resident taxpayers, regardless of the source of income. Foreign and temporary residents are excluded from this threshold.
    Income Tax The UK operates progressive rates of income tax which include:

    • £0 to £12,570 (personal allowance) – 0%
    • £12,571 to £50,270 (Basic rate) – 20%
    • £50,271 to £150,000 (Higher rate) – 40%
    • Over £150,000 (Additional rate) – 45%

    Australia operates progressive rates of income tax which include:

    • $0 to $18,200 – Nil
    • $18,201 to $45,000 – 19%
    • $45,001 to $120,000 – 32.5%
    • $120,001 to $180,000 – 37%
    • $180,001 and over – 45%

    The income tax rates above are for ‘Australian’ Residents only. Different rates apply for ‘temporary’ and ‘foreign’ residents.
    Capital Gains Tax

    In the UK there is a Capital Gains Tax allowance of £12,300 per year (2022-23). After this your tax rate will depend on whether you’re a ‘Basic rate’ tax payer or ‘Higher rate’ tax payer:

    Basic Rate: 18% on residential property and 10% other chargeable assets

    Higher Rate: 28% on residential property and 20% other chargeable assets

    There is a 50% Capital Gains Tax discount for Australian individuals who own an asset for 12 months or more. This means you pay tax on only half the net capital gain on that asset.

    Taxable Capital Gains are added to the individuals assessable income and are taxed at the marginal rate at which the income falls.
    Inheritance Tax In the UK, the standard Inheritance Tax threshold is £325,000 (which can increase to £500,000 where the home is passed to children of the deceased). Where an estate is valued over £325,000 there is a 40% Inheritance Tax rate. Australia does not have any Inheritance Tax.
    Tax Return Deadline 31 January following the end of the tax year (31 October if filing a paper return). In Australia, the due date is 31 October following the end of the tax year. However, if an individual is registered with a tax agent this will usually extend to 15 May of the following year i.e. tax-year end 30 June 2022 would be due 15 May 2023.
    Tax Payment Deadline 31 January following the end of the tax year. This is the same as the tax return deadline.

    In Australia, the tax payment deadline depends on when the tax return is due and the date it is lodged. Where a tax return is due 15 May, the following payment dates will apply when the tax return is lodged:

    • Up to and including 12 February, the payment date is 21 March
    • From 13 February to 12 March, the payment date is 21 April
    • From 13 March, the payment date is 5 June

    If the tax return is not due by 15 May, the payment will be due on the later of 21 days after the:

    • Relevant lodgement due date, or
    • Notice of assessment is deemed received
    Assessable on Worldwide Income UK residents, for tax purposes are taxed on their worldwide income*.

    Australian residents for tax purposes, are also taxed on their worldwide income.

    ‘Foreign’ and ‘temporary’* residents for tax purposes only need to declare income and gains derived in Australia.
    National Insurance/ Medicare In the UK, both the employee and employer are required to pay national insurance contributions each month. The rates vary from 0% to 13.8%. National Insurance is also due on self-employed income. In Australia, individuals must pay a flat rate of Medicare (unless exempt). The Medicare levy is 2% of an individual’s taxable income. An additional Medicare levy of up to 1.5%, unless they pay for private health insurance.

    *Assessable on worldwide income (UK) – Individuals resident of the UK with non-domicile status can opt to claim remittance basis and not be taxed on their overseas income as long as it is not remitted to the UK.
    *Assessable on worldwide income (AUS) – Individuals who are ‘temporary’ resident will also be taxable on income earned from employment or services performed overseas whilst temporary resident.

    The UK and Australian Tax Systems: An Overall Comparison

    Determining which country has the more competitive tax system is no easy task.

    Although income tax is generally lower in the UK (due to the progressive tax bandings), the Australian system includes a considerably lesser Medicare tax in comparison to the UK’s National Insurance rates. What’s more, where Australia allows a 50% discount on net taxable Capital Gains, the rate at which Capital Gains tax is payable in the UK may be under half of what individuals could be liable to pay in Australia (if their annual income exceeds the top tax bracket in Australia).

    In addition, establishing whether an individual is an ‘Australian’, ‘foreign’ or ‘temporary’ tax resident of Australia, or their ‘domicile’ status when tax resident of the UK, heavily dictates their tax liability due at the end of the tax year.

    Since 1978, Australia’s tax system has operated with no inheritance tax –which saw Australia as the first developed country to abolish death duties. In stark contrast, the UK still maintains an aggressive tax rate of 40% above the inheritance tax threshold. It is evident that, where an individual’s assets equate to more than £325,000 on death, the Australian tax system is significantly more attractive.

    As the tax systems in the UK and Australia are extremely different, it requires in-depth analysis to understand how each system operates and the implications which might then present for an individual on a case-by-case basis.

    If you require any advice or assistance with UK or Australian personal tax, we are here to help. Simply send us an email at the address below or fill in our contact form to arrange a free initial consultation.

    For enquiries please contact:
    Ned Shelton
    Director
    Sheltons Accountants
    N.Shelton@SheltonsGroup.com

    Click here to read our blog in regard to renting out your UK property whilst living in Australia.

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