100kEUR ETF investment & DK Exit tax
I am living in Denmark since 2024 and expect to move back to my home EU country in ~2 years. I currently have ~€100k in an accumulating S&P 500 ETF and invest another €2.5–3k/month.
The ETF is held in a normal account (not ASK) and is not on SKAT’s positive list, so it is subject to Danish lagerbeskatning: annual tax on unrealized gains, potentially around 40%+ in my situation.
I’m considering selling it, paying the ~€6k tax already due, and reinvesting into ~20–25 individual stocks that broadly replicate the S&P 500. Ordinary shares are realization-taxed, so I would hold them without selling for the next ~2 years.
Since I expect to leave Denmark after ~5 years of tax residency, i.e. before the 7-year threshold for normal Danish share exit tax, my understanding is that I could move to to my home country still holding those unrealized gains without Danish exit tax.
Am I missing anything?
TL;DR: Pay existing ETF tax now → switch €100k to individual S&P-like stocks → avoid annual Danish tax on future unrealized gains → hold until moving back to home country before 7 years.