Tax matters

Published:

27.03.2024

The Carlsberg Foundation is classified as an enterprise foundation on account of its shareholding in Carlsberg A/S. Our revenue consists of dividends from Carlsberg A/S and the return on our financial investments. The vast majority of this revenue is distributed as grants and donations for basic research and the other objects set out in our charter.

The taxation of enterprise foundations is subject to numerous special rules, but can be summed up as follows:

  • In principle, the Carlsberg Foundation is taxed under the same rules as Danish companies.

  • However, foundations are permitted to offset charitable donations against their taxable income. This means that the Carlsberg Foundation is able to offset grants for basic research, research at the Carlsberg Research Laboratory, the museum operations of the Frederiksborg • Museum of National History , and donations from the Tuborg Foundation for socially beneficial purposes.

  • The Carlsberg Foundation’s revenue consists of dividends from Carlsberg A/S and the return on its other investments.

  • Carlsberg A/S pays corporate income tax on its profits before they are paid out as dividends to the foundation and other shareholders. The current corporate income tax rate in Denmark is 22 per cent.

  • The dividends that the Carlsberg Foundation receives are tax-free in principle, but count when offsetting the foundation’s charitable donations, etc.

  • The return on the foundation’s other investments and other income is taxable at a rate of 22 per cent.

  • For as long as the foundation continues to make substantial donations on a par with dividends received on the foundation’s shares in Carlsberg A/S and the return on the foundation’s other investments, the foundation will not itself pay any tax.

Taxation of grant awards

The recipients of grants from the Carlsberg Foundation are taxed differently according to who they are:

  • Private individuals who are liable to tax in Denmark will typically pay up to 56 per cent tax on grants received.

  • Danish companies receiving grants from the foundation will pay 22 per cent corporate income tax on these grants.

  • Public institutions and museums receiving grants from the foundation will not normally pay any tax on these grants. However, if the institution uses a grant to pay salaries to individuals who are liable to tax in Denmark, tax will be payable at this point.Grant recipient: private individual

Grant recipient: private individual

The Carlsberg Group’s income is taxed under the standard Danish rules on corporate taxation, illustrated below using the current Danish corporate income tax rate of 22 per cent. Every DKK 100 distributed in dividends to the Carlsberg Foundation therefore requires taxable income at Carlsberg A/S of DKK 128.

The DKK 100 received by the foundation may then be distributed as a grant to an individual who is liable to tax in Denmark. As explained in the overview above, the foundation itself does not pay any tax if its revenue is distributed as charitable grants and donations.

The person receiving the grant will pay ordinary income tax, which is set in the example below at 56 per cent. The recipient therefore receives DKK 44 after tax of Carlsberg A/S’s original taxable income of DKK 128.

Grant recipient: company

The Carlsberg Group’s income is taxed under the standard Danish rules on corporate taxation, illustrated below using the current Danish corporate income tax rate of 22 per cent. Every DKK 100 distributed in dividends to the Carlsberg Foundation therefore requires taxable income at Carlsberg A/S of DKK 128.

The DKK 100 received by the foundation may then be distributed as a grant to a Danish company. As explained in the overview above, the foundation itself does not pay any tax if its revenue is distributed as charitable grants and donations.

The company receiving the grant will pay ordinary corporate income tax, which is set in the example below at 22 per cent. The company therefore receives DKK 78 after tax of Carlsberg A/S’s original taxable income of DKK 128.

Grant recipient: researcher

The Carlsberg Group’s income is taxed under the standard Danish rules on corporate taxation, illustrated below using the current Danish corporate income tax rate of 22 per cent. Every DKK 100 distributed in dividends to the Carlsberg Foundation therefore requires taxable income at Carlsberg A/S of DKK 128.

The DKK 100 received by the foundation may then be distributed as a grant to a researcher via a university. As explained in the overview above, the foundation itself does not pay any tax if its revenue is distributed as charitable grants and donations.

The university receives the grant tax-free and so will not itself pay any income tax. If the grant is paid out to researchers who are liable to tax in Denmark, they will then pay income tax at up to around 56 per cent. The recipient therefore receives DKK 44 after tax of Carlsberg A/S’s original taxable income of DKK 128.