Registering a Georgian Individual Entrepreneur and getting Small Business Status is the fast part of this move, and Georgia's 1% rate is real. What decides whether that rate is actually yours is a question Danish law asks, not Georgian law: does Denmark still consider you fully tax liable, and the answer turns on a single fact almost every guide undersells. Denmark's full tax liability rule cares about whether you have kept a home available, not about how many days you actually spend there. This guide works through what Danish law actually requires before the 1% is legally yours.
What a self-employed Dane actually pays, here and there
Start with the number, because it is the reason anyone reads this far.
A self-employed Dane with DKK 750,000 of business profit pays AM-bidrag, the labour market contribution, at a flat 8% before anything else is calculated, confirmed by PwC's Denmark tax summary: DKK 60,000. What is left, DKK 690,000, is then taxed as personal income: bundskat at 12.01%, plus municipal tax at the national average of 25.049%. At this income level the mellemskat threshold of DKK 696,956 is not yet crossed, so neither mellemskat nor topskat applies.
| Denmark (self-employed, 2026) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Turnover / net profit | DKK 750,000 | DKK 750,000 |
| AM-bidrag (8%) | ~DKK 60,000 | - |
| Bundskat (12.01%) | ~DKK 82,900 | - |
| Municipal tax (national average, ~25.05%) | ~DKK 172,800 | - |
| Georgian tax (1% of turnover) | - | DKK 7,500 |
| Total | ~DKK 316,000 (~42%) | DKK 7,500 (~1%) |
That gap, roughly 42% against roughly 1%, is the entire reason this guide exists, and exactly why Danish law does not let it happen the moment someone books a flight.
Does the 1% actually apply to your income in the first place
Before any of the Danish math matters, the 1% has to genuinely apply, which is a Georgian-side question first. Small Business Status taxes Georgian-source income, and for services that generally means work physically performed in Georgia, not work billed through a Georgian registration while sitting in Copenhagen or Aarhus. We cover the mechanics fully in Georgia's 1% tax and the source test in Georgian-source income rules. What changes for a Danish national specifically is everything downstream: whether Denmark still considers you fully liable, and what it charges on the way out if it does.
What Denmark does when you leave
Full tax liability under kildeskatteloven § 1 depends primarily on bopæl, having a home available in Denmark, not on a day count. SKAT's own guidance is explicit that where a taxpayer retains control over a year-round dwelling after relocating, that is normally sufficient on its own to treat the residence as maintained, regardless of how rarely you actually use it, unless the facts clearly show an intention to settle permanently abroad.
Moving abroad does not end Danish full tax liability by itself. What ends it is genuinely giving up the Danish home, selling it, or letting it out under a lease that removes your own right to use it, not simply living elsewhere while keeping a flat or a house "just in case." Keep any Danish dwelling under your control and Denmark can treat you as fully liable regardless of how few days a year you actually spend there. Separately, even someone with no Danish home at all becomes fully liable again if they stay in Denmark for six months or more, short trips abroad for holidays included.
Denmark also runs a genuine exit tax on shares under aktieavancebeskatningsloven § 38, confirmed on skat.dk's own guidance. If you have been liable to Danish tax on share gains for at least 7 of the last 10 years, shares and other qualifying securities are treated as sold at market value the moment full liability ends, but only above a DKK 100,000 threshold. Payment can be deferred, generally as the shares are actually disposed of rather than all at once, with an annual holdings statement due each year the balance remains outstanding. This is a real bill triggered by departure, and it needs settling before you leave, not discovered afterward.
Denmark's personal CFC rule, Ligningsloven § 16 H, set out in the statute itself, reaches an individual who controls a foreign company with predominantly mobile or financial income taxed at a low rate, mirroring the logic of Denmark's corporate CFC rule. A Georgian Individual Entrepreneur is a sole-proprietorship registration, not a company, so there is no separate entity for this rule to attach to. A Georgian LLC is a company, and its 0% tax on retained profit is exactly the kind of low-taxation position this rule is built to reach if a Danish resident controls it.
Denmark and Georgia have had a double taxation treaty in force since 23 December 2008, confirmed on Georgia's Ministry of Finance treaty list, giving a tie-breaker to fall back on once residency is actually disputed. Denmark has maintained its own national list of non-cooperative jurisdictions since 1 July 2021, but it currently tracks the EU list, and Georgia is not on either, so there is no Danish blacklist issue here.
The steps, in order
- Decide what happens to the Danish home before you leave, not after. Selling it, or letting it out on terms that remove your own right to use it, is what actually closes this tie.
- If any Danish dwelling stays under your control even briefly, plan around it deliberately, since it is normally enough on its own to preserve full liability regardless of days spent there.
- Track presence carefully if you have no remaining Danish home, since six months or more in Denmark in a rolling period, short holiday trips included, retriggers full liability from scratch.
- Value your share and security holdings against the 7-of-last-10-years test and the DKK 100,000 threshold before departure, since the exit tax is calculated as at the day full liability ends.
- Decide whether to defer the exit tax and diarise the annual holdings filing for as long as a deferred balance remains outstanding.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over an LLC if Ligningsloven § 16 H exposure is a live concern, since an IE generally sits outside the rule while a Georgian LLC does not.
- Confirm your Georgian tax residency position separately from the business registration itself, since holding Small Business Status does not by itself make you tax resident here.
Timeline and cost
The Georgian side is fast: an IE with Small Business Status is typically registered within days in person, or two to three weeks under power of attorney. The Danish side sets the real pace, and it hinges almost entirely on the home: selling a property, ending a lease properly, or making sure nobody in the household retains a right to use it can take months to arrange cleanly, and it is worth finishing before the move rather than treating it as a loose end.
The verdict for a Danish national
Georgia works with conditions for a Danish national, and the condition is concrete rather than abstract: the home has to genuinely go. If the Danish dwelling is sold or properly let with no reserved right to use it, days in Denmark are kept well under the six-month threshold, and any exit-tax exposure on shares is settled before departure, the 1% is legally durable. If a flat is kept "for visits" or "in case things don't work out," full Danish tax liability rarely actually ends, and the Georgian registration sits on top of a Danish tax position that never really closed.
We'll work through whether your Danish home genuinely ends full tax liability, what your exit-tax exposure looks like against the DKK 100,000 threshold, and whether an IE or an LLC is the right call given Ligningsloven § 16 H, before you register anything here. Written summary included.
See what it costs
For the same analysis built for a Finnish departure, see moving from Finland to Georgia, and for a Norwegian one, see moving from Norway to Georgia. Our country-by-country guide compares the treaty position and headline trap for every country we cover.
Key takeaways
- A self-employed Dane on DKK 750,000 of profit pays roughly 42% all-in at home versus roughly 1% under Georgian Small Business Status.
- Full Danish tax liability turns on whether you keep a home available, not on days present. A retained year-round dwelling is normally enough on its own to preserve it.
- Without any Danish home, six months or more of presence in Denmark, short holiday trips included, retriggers full liability.
- Denmark's exit tax on shares applies above a DKK 100,000 threshold once you have been liable on share gains for 7 of the last 10 years, with deferral available rather than an immediate bill.
- Ligningsloven § 16 H generally does not reach a Georgian IE but can reach a Georgian LLC controlled by a Danish resident.
- Denmark and Georgia have had a tax treaty in force since 2008, and Georgia is on neither the EU list nor Denmark's own non-cooperative list.
Frequently asked questions
Does moving to Georgia automatically end my Danish tax residency?
No. Full Danish tax liability generally ends only when you have genuinely given up any home available to you in Denmark, or, absent a home, when you stay under the six-month presence threshold. Registering a Georgian business changes nothing about this on its own.
Why does keeping a Danish apartment matter more than how many days I spend there?
Because full liability under kildeskatteloven § 1 is primarily a bopæl, or dwelling, test. SKAT's own guidance treats retained control over a year-round home as normally sufficient on its own to preserve full liability, regardless of how rarely it is actually used.
What if I have no home in Denmark at all?
A different limb applies. Someone with no Danish dwelling becomes fully liable again if they stay in Denmark for six months or more, including short trips abroad for holidays that do not break the period.
What is Denmark's exit tax on shares and when does it apply?
Under aktieavancebeskatningsloven § 38, shares and similar securities are treated as sold at market value the day full Danish tax liability ends, if you have been liable to Danish tax on share gains for at least 7 of the last 10 years and the gain exceeds DKK 100,000.
Can I defer paying the Danish exit tax?
Generally yes. Deferral is available so the tax is paid roughly as the shares are actually disposed of, rather than in full at departure, though an annual holdings statement is required for as long as the deferred balance remains outstanding.
Does Danish CFC law reach a Georgian Individual Entrepreneur?
Generally not. Ligningsloven § 16 H reaches an individual who controls a foreign company with predominantly mobile or financial income. A Georgian IE has no separate legal personality, so there is no company for the rule to attach to.
Does the same apply to a Georgian LLC?
No. A Georgian LLC is a company, and its 0% tax on retained profit is exactly the low-taxation position Ligningsloven § 16 H is built to reach if a Danish resident controls it.
Is Georgia on Denmark's blacklist?
No. Denmark has maintained its own national list of non-cooperative jurisdictions since 1 July 2021, but it tracks the EU list, and Georgia does not appear on either.
Does the Denmark-Georgia tax treaty stop full Danish liability from applying?
No. The treaty, in force since 2008, resolves a dispute once both countries have a genuine claim on the same person in the same year. It does not switch off the dwelling test, which decides whether that claim exists at all under domestic Danish law.
Is a Georgian IE or an LLC the better structure for a Danish national?
For most solo movers with real CFC concerns, the IE is simpler, since it generally sits outside Ligningsloven § 16 H entirely. An LLC still makes sense for other reasons, liability separation or multiple owners among them, but it needs a real look at the CFC exposure first rather than being assumed safe by default.