Do my heirs pay Danish inheritance tax (boafgift)?
Short answer: Denmark charges boafgift at 15% on the value of an estate above an annually adjusted tax-free allowance, with spouses exempt entirely, and a supplementary 25% charge applying on top for beneficiaries outside the close family group. There is no comprehensive US–Denmark estate tax treaty, so Danish boafgift and US estate tax can both apply to the same assets with limited coordination.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-10-09.
Why it works this way
Danish law sets the base boafgift rate at 15% of the estate value above a tax-free threshold that is adjusted each year — 346,000 kr for 2025 — with transfers between spouses fully exempt from boafgift [1](https://skm.dk/tal-og-metode/satser/satser-og-beloebsgraenser-i-lovgivningen/boafgiftsloven). An additional supplementary charge of 25% applies to the portion passing to beneficiaries who are not close relatives — broadly, people other than children, stepchildren, parents, or a defined set of close connections — on top of the base rate [2](https://www.retsinformation.dk/eli/lta/2023/11/pdf).
A 2024 reform increases the tax-free threshold from 2026 and removes the supplementary charge for inheritance passing to siblings from 2027, narrowing the scope of the higher rate over time [3](https://skm.dk/media/apqahpml/faktaark-9-boafgift.pdf).
For a US citizen, the key gap is that the US and Denmark do not have a comprehensive estate and gift tax treaty — only the income tax treaty, which does not generally address estate tax allocation. That means a US-resident child inheriting Danish assets, or a Danish-resident heir inheriting US-situs assets, can face both countries' rules applying without a treaty mechanism to prevent double taxation.
The US side has its own separate complication for a non-US-citizen spouse: the usual unlimited US marital estate tax deduction does not apply without a qualified domestic trust (QDOT), which matters directly for a US citizen married to a Danish national.
The expensive mistake: Assuming a US will is enough, or that boafgift won't apply because the heir lives in the US
Danish boafgift can apply based on where the deceased or the assets were situated, regardless of where the heir lives, and a US will does not automatically control Danish-situs assets. Cross-border estate planning needs both a Danish and a US document, coordinated deliberately.
What to do
- Map which assets are Danish-situs and which are US-situs — Boafgift and US estate tax exposure depend partly on where each asset sits, not only on residence.
- Check whether a QDOT is needed for a non-US-citizen spouse — Without one, the usual unlimited US marital deduction is unavailable.
- Put both a Danish and a US will in place, drafted to work together — A single will drafted under one country's law can fail to control assets situated in the other.