The section covers

• Rule
• Commencement of tax liability
• Cessation of tax liability

The basis of taxation comprises yields from the year of taxation. The year of taxation is the calendar year. If a pension plan has more than one holder, the yields determined are distributed in proportion to the share of the pension plan assets held by the holders in question at the end of the year of taxation. See Section 11(1) of PAL.

On commencement of the tax liability under Section 1 of the Danish Pension Investment Return Tax Act (Pensionsafkastbeskatningsloven (PAL)), in the first year of taxation, the basis of taxation comprises the asset yields to which a right is acquired in the period from the time of commencement of the tax liability up to and including 31 December in the year of taxation. See Section 11(2) of PAL.

If the tax liability commences on 1 April 2008, the tax for the 2008 year of taxation is based on the taxable yields from assets to which a right is acquired in the period 1 April to 31 December 2008.

On cessation of the tax liability under Section 1 of PAL, the basis of taxation in the last year of taxation includes the yields from assets to which a right is acquired in the period from 1 January to the time of cessation of the tax liability. See Section 11(2) of PAL.

If the tax liability under Section 1 of PAL ceases on 1 September 2008, the tax for the 2008 year of taxation is based on the taxable yields from assets to which a right is acquired in the period 1 January to 1 September 2008.