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Quick Summary
The Skat positive list determines whether your ETF or investment fund is taxed as aktieindkomst (27/42%) or the less favourable kapitalindkomst (roughly 37–42%). If your fund isn’t on it, you’re paying more tax on the same returns. Relevant to all Danish tax residents investing in ETFs or foreign funds for frie midler (non-pension, non-ASK accounts). The 2026 list contains over 5,000 funds. Gains on listed funds are taxed at 27% up to DKK 79,400 (for singles) and 42% above that threshold.
What Is the Skat Positive List?
The positive list (officially: Liste over aktiebaserede investeringsselskaber) is published by Skatteforvaltningen. It’s a register of investment funds that have notified Skat they are equity-based, meaning at least 50% of the fund’s assets are held in equities on average throughout the calendar year.
That 50% threshold is the whole mechanism. If a fund meets it and reports to Skat, the fund goes on the list. If it doesn’t, it stays off.
The list applies for the entire tax year. Skat typically publishes the initial version in December for the following year, then issues updates throughout the year as new funds register. The 2026 list was first published on 15 December 2025 and now contains over 5,000 funds.
One detail that confuses people: Danish distributing investment funds (investeringsforeninger like Sparindex) don’t need to be on the positive list to be taxed as aktieindkomst. They’re covered by separate rules. The positive list matters primarily for ETFs and foreign funds.
Why It Matters: Aktieindkomst vs Kapitalindkomst
The positive list controls which tax category your fund’s gains fall into. Both categories use lagerbeskatning (mark-to-market taxation, assessed annually), but the rates are different. We cover capital gains in Denmark deeper in our guide.
| On the positive list | Not on the positive list | |
| Tax category | Aktieindkomst | Kapitalindkomst |
| Tax rate | 27% / 42% (progressive) | Approx. 37–42% (depends on total income and deductions) |
| Threshold (single) | DKK 79,400 | Varies |
| Threshold (couple) | DKK 158,800 | Varies |
| Taxation method | Lagerbeskatning (annual) | Lagerbeskatning (annual) |
| Loss deduction | Against other aktieindkomst | Against other kapitalindkomst |
| ASK eligible | Yes | No |
In practice, the difference is sharpest for investors with modest gains. If your annual ETF gains are under the aktieindkomst threshold, you’re paying 27% on the positive list vs roughly 37% off it. That’s a 10 percentage point gap on the same return.
In Short
Fund on the list: taxed as aktieindkomst at 27/42%. Fund off the list: taxed as kapitalindkomst at roughly 37–42%. Same gains, different bill.
What’s On the List (and What’s Not)
The 2026 list runs to over 5,000 funds from 9 countries. The majority are domiciled in Luxembourg and Ireland (the standard domiciles for European UCITS ETFs). Around 900 of them are passive index funds with low fees: the type most retail investors are actually looking for.
The big providers are well represented. iShares (BlackRock) has around 500 funds on the list. Xtrackers (DWS) has over 160. Amundi has 85. SPDR (State Street) joined in 2026 with 8 ETFs, including the popular SPDR MSCI ACWI IMI UCITS ETF.
The conspicuous absentees: Vanguard, Invesco, and Franklin are not on the list. None of their UCITS ETFs have been registered as equity-based with Skat. If you hold a Vanguard FTSE All-World or an Invesco S&P 500 ETF in a Danish frie midler account, your gains are taxed as kapitalindkomst.
Tip
If you’re choosing between two similar global index ETFs and one is on the positive list while the other isn’t, the fund on the positive list will almost always be cheaper after tax. A marginally higher TER on a listed fund is usually wiped out by the tax saving.
How to Check If Your Fund Is On It
Skat publishes the raw Excel file on their IFPA page. Download it, find the tab for the current year, and search for your fund’s ISIN. The ISIN is the 12-character code you’ll find on your broker’s fund detail page or on justETF.
If you’re on Nordnet or Saxo, the platform usually flags a fund’s tax status. But don’t rely solely on broker labels: verify against the official list, especially for funds you’ve held across year boundaries.
What Happens When a Fund Drops Off the List?
Funds can be removed. It’s uncommon (around 30 were dropped for 2026), but it happens. When a fund leaves the list, its tax classification changes from 1 January of the new year. There’s no grandfathering: your existing holding switches to kapitalindkomst treatment going forward.
Skat doesn’t send a notification when a fund is removed. It simply disappears from the next version of the file. This is why checking the list at the start of each year is worth the two minutes it takes.
Check The List
Check once a year. If your fund dropped off, your gains from 1 January are taxed as kapitalindkomst. No warning, no grace period.
The ASK Connection
The aktiesparekonto (ASK) only accepts securities taxed as aktieindkomst. For ETFs, that means they must be on the positive list. You can’t hold a Vanguard ETF in your ASK, because Vanguard isn’t on the list. The ASK contribution limit for 2026 is DKK 174,200, taxed at a flat 17%.
Americans: The Positive List Doesn’t Override PFIC Rules
If you’re a U.S. citizen or green card holder, the positive list solves the Danish tax classification, but it does nothing about PFIC (Passive Foreign Investment Company) rules on the American side. Almost every non-U.S.-domiciled fund qualifies as a PFIC under IRS rules, which means punitive U.S. tax treatment regardless of what Skat says.
The interaction between Danish aktieindkomst treatment and U.S. PFIC rules is one of the most common traps for American expats investing in Denmark. The two tax systems don’t align, and the cost of getting it wrong compounds annually. Talk to a cross-border tax adviser before opening positions in any non-U.S. fund. For the full picture, see our PFIC guide.
Bottom Line
The positive list is a small piece of bureaucracy with an outsized effect on your investment returns. Pick a listed fund, and your gains are taxed at 27% up to the threshold. Pick an unlisted one, and you’re looking at 37–42% from the first krone. For most expats investing in ETFs through a frie midler account, sticking to the positive list is one of the simplest tax optimisations available. Check the list once a year, verify your holdings, and move on.
Disclaimer
This article is for informational purposes only and does not constitute financial, tax, or investment advice. Figures reflect publicly available data at time of writing. Always consult a qualified professional regarding your specific situation. See our full disclaimer.
