Who Pays Income Tax When a Pole Works Seasonally in Denmark 2026

Every spring and summer, thousands of Polish workers cross into Denmark for seasonal contracts in agriculture, construction and hospitality. The question that follows them as surely as their first payslip is: who actually pays income tax when a Pole works seasonally in Denmark, and does the grænsegangerregler rule apply or does full Danish tax residency kick in? Getting this wrong can mean unexpected back-taxes, penalties from SKAT, or a nasty surprise when filing in Poland. This guide walks through the key steps for 2026.

Step 1: Understand the Two Tax Positions

Before anything else, a worker and their employer need to know which legal category applies. Danish tax law recognises two distinct situations for foreign nationals earning income in Denmark.

The first is full tax residency (fuld skattepligt). This applies when a person establishes a genuine home in Denmark or stays in the country for a continuous period exceeding six months. A full tax resident pays Danish income tax on their worldwide income, and Denmark becomes the primary taxing state under the Denmark-Poland Double Taxation Convention.

The second is limited tax liability (begrænset skattepligt), which covers workers who live in Poland and commute or travel to Denmark for short-term contracts. Under this status, only income earned in Denmark is taxed in Denmark, while Poland retains the right to tax other income. The so-called grænsegangerregler provisions, which once offered special relief to cross-border workers living close to the Danish border, were significantly changed by Danish legislation, so workers should not assume those older rules automatically apply to them.

Step 2: Check Your Residency Status Before You Start Work

The single most important document a seasonal worker should obtain before their first working day is a Danish tax card (skattekort) from SKAT. Without it, the employer is legally required to withhold tax at the maximum rate, which can be a severe financial shock on a short contract.

To apply for a tax card, the worker must first register with the Danish Civil Registration System and obtain a CPR number. Registration is handled through the local municipality (kommune). SKAT then uses the information provided to determine whether the worker falls under full or limited liability and issues the appropriate tax card accordingly.

Workers who maintain their permanent home in Poland, return there regularly during the contract, and do not establish a dwelling in Denmark will typically be placed under limited tax liability. However, if a worker rents an apartment in Denmark and stays without returning to Poland for more than six consecutive months, SKAT may reclassify them as a full tax resident. This is not a theoretical risk. SKAT has the authority to audit residency status, and the burden of proof lies with the worker.

Step 3: Gather the Required Documents

Whether applying for a tax card or later filing a Danish tax return, a seasonal worker will need a valid passport or EU identity card, proof of Polish address (such as a utility bill or a certificate of residence from the Polish civil registry), the employment contract with the Danish employer, and bank account details for any potential refund. Workers who have already paid social insurance contributions in Poland and hold an A1 certificate issued by ZUS should bring that document as well, since it confirms that social security remains in Poland and prevents double contributions.

For those who qualify under limited tax liability and want to claim deductions such as the personal allowance (personfradrag), a separate application must be submitted to SKAT. This is not automatic. Missing this step is one of the most common and costly errors made by first-time seasonal workers.

Step 4: Register with SKAT and Submit Your Tax Card Application

The application for a CPR number and tax card can be started online via the SKAT website, but most workers will need to appear in person at a Borgerservice office to verify their identity. Processing times vary by municipality, so this step should be completed as early as possible, ideally before the contract start date.

Once the tax card is issued, the worker hands it to their employer, who then withholds the correct amount of A-skat (preliminary income tax) from each payslip. The employer's obligation to report and remit this tax to SKAT is governed by Danish tax administration law and cannot be transferred to the worker.

For context on how Danish employment obligations interact with pay, it is worth reading about Minimum Wage on Danish Construction Sites 2026: 3F Rates, Night and Holiday Supplements Step by Step, since gross pay levels directly affect the amount of A-skat withheld.

Step 5: File Your Annual Tax Returns in Both Countries

Denmark operates a pre-filled tax return system. After the tax year ends, SKAT sends each registered worker a preliminary assessment (årsopgørelse) through the e-Boks digital mailbox. Workers should review this carefully. If deductions were missed during the year, they can be added at this stage, and any overpayment is refunded automatically.

In Poland, the worker must also file a PIT return. Under the Denmark-Poland Double Taxation Convention, income taxed in Denmark is generally exempt from Polish income tax, but it must still be declared in Poland because it affects the applicable tax rate on any remaining Polish income. The Polish tax authority (Urząd Skarbowy) and the podatki.gov.pl portal provide guidance on how to report foreign income correctly.

Workers on posted contracts should also be aware of their leave entitlements, which are covered in detail in the article on Annual Leave for Posted Polish Workers in Denmark 2026.

Common Mistakes to Avoid

One of the most frequent errors is assuming that a short contract means no Danish tax obligation at all. Even a single day of paid work in Denmark creates a limited tax liability, and failing to register can lead to the employer withholding at the maximum rate with no possibility of a refund until a formal return is filed.

Another mistake involves the A1 certificate. Some workers obtain it from ZUS but never present it to the Danish employer, leading to unnecessary Danish social contributions being deducted alongside Polish ones. The A1 certificate must be shown before the first payslip is generated.

Workers who are dismissed before their contract ends face additional complexity, since the final payslip, any holiday pay settlement and potential severance must all be reported correctly in both countries. The article on Dismissing a Polish Worker in Denmark 2026: Notice Periods, Arbejdsret and What to Avoid explains the Danish side of that process.

Actionable Advice for 2026

Register with the local Danish municipality and apply for your CPR number and tax card before you start work, not after. Obtain an A1 certificate from ZUS in Poland if your social security remains there. Keep copies of your Polish address documentation throughout the contract. After the Danish tax year closes, log into e-Boks to check your årsopgørelse and claim any deductions you missed. Finally, file your Polish PIT return on time and declare your Danish income in the correct section for foreign earnings. These five steps will keep you compliant on both sides of the border and protect you from penalties that can otherwise follow you for years.