1. Country Overview
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1967: VAT Introduced – Denmark implements its first VAT Act (effective 3 July 1967), replacing earlier sales taxes.
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1973: EU Membership – Denmark joins the European Economic Community (now EU), paving the way to align VAT rules with European directives.
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1994: Modern VAT Law – The present Danish VAT Act (Momsloven) takes effect from 1 July 1994, consolidating and updating VAT rules.
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2007: EU Directive Alignment – Danish VAT legislation is fully aligned with the EU VAT Directive 2006/112/EC (effective 1 Jan 2007).
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2010: VAT Package Changes – Denmark implements the EU “VAT Package” reforms (effective 1 Jan 2010), updating place-of-supply rules for services in line with EU law.
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2021: E-commerce Reforms – The EU e-commerce VAT package takes effect (1 July 2021), introducing OSS simplifications and a single EU distance sales threshold.
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2024–2026: Digital Compliance – A phased rollout of Denmark’s new Bookkeeping Act requirements introduces certified digital bookkeeping, e-invoicing readiness, and SAF-T data standards by 2026.
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2026: Zero VAT on Books – As part of a literacy initiative and new EU flexibilities, Denmark plans to zero-rate books from 2026 (reduced from 25%).
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2028: Planned Food VAT Cut – The government aims to introduce a reduced VAT rate on basic foodstuffs by 2028 (e.g. 15%), pending final decisions.
2. Local VAT Term
3.1 Standard Rate
3.2 Reduced Rates (with examples)
3.3 Zero-Rated and Exempt Supplies
- Exports of goods to outside the EU, and intra-Community supplies of goods to VAT-registered customers in other EU states, are zero-rated (VAT not charged, but seller retains the right to deduct input VAT). [taxsummaries.pwc.com]
- Certain forms of international passenger transport: e.g. travel by air or sea from Denmark to destinations abroad (and even domestic flights, due to a special Danish provision) are treated as zero-rated. [vatcalc.com]
- Supplies to ships and aircraft: goods and services for use on board vessels navigating in international waters or international flights can qualify for 0%. [vatcalc.com]
- Sales of investment gold to central banks are zero-rated. [vatcalc.com]
- Newspapers (traditional print newspapers) are zero-rated in Denmark. This long-standing policy supports media by not taxing newspapers while still allowing publishers to reclaim input VAT. [vatcalc.com]
- A few other activities like qualifying charitable activities, certain cultural services, and burial services are listed under VAT Act §34 as zero-rated (effectively VAT-exempt with credit). [vatcalc.com]
- Health, medical care, and hospital services (medical treatment). [taxsummaries.pwc.com]
- Education and training services (school and university tuition). [vatcalc.com]
- Financial services: banking, insurance, reinsurance, credit granting, etc.. [taxsummaries.pwc.com]
- Insurance services. [taxsummaries.pwc.com]
- Certain cultural and social services provided by non-profits or public bodies (social welfare, etc.). [vatcalc.com]
- Postal services by the national postal service (ordinary mail deliveries). [vatcalc.com]
- Lotteries, betting and gambling activities (state-licensed). [vatcalc.com]
- Sale or rental of immovable property (real estate) is generally exempt, except for new buildings and building land which are taxable by law. (Denmark does allow optional VAT on certain property rentals by election, not mentioned here.) [vatcalc.com]
- Passenger transport that is international (e.g. international rail/bus) is treated as exempt in Denmark (somewhat unusually, as many countries zero-rate such transport). Domestic public transport (like buses, trains) is generally taxable at 25%, not exempt, except for the special case of domestic flights noted earlier. [vatcalc.com]
3.4 Recent or Upcoming Rate Changes
4. VAT Number Format
- The “DK” prefix is used for international purposes (e.g. on invoices for intra-EU sales, VIES checks). Domestically, the number is often just referred to as CVR and written without “DK”.
- Format: 8 digits (no letters after the country code). The first digit cannot be 0 (as CVR numbers don’t start with 0).
5. Registration Requirements
5.1 Registration Thresholds for Residents and Non-Residents
- Businesses making only exempt supplies (e.g. purely financial or medical services) do not register for VAT, since those activities are outside the VAT system.
- If a company is only involved in distance selling to consumers or digital services, see sections 18 and 17 respectively for thresholds (OSS scheme can apply).
- Intra-Community acquisition threshold: If a Danish entity that is not VAT-registered (e.g. a small exempt business or a charity) purchases goods from other EU countries, a threshold of DKK 80,000 per year applies; above that, they are required to register and self-account for VAT on those acquisitions. (This prevents medium-sized unregistered entities from avoiding VAT by buying abroad.) [vatcalc.com]
- Distance sales to Denmark (by foreign EU sellers): Historically, Denmark had a distance selling threshold of around DKK 280,000/year for goods sold to consumers, but since 2021 this is replaced by the EU-wide €10,000 threshold (see section 18). Now effectively any foreign EU seller must charge Danish VAT on B2C sales if total EU-wide B2C sales exceed €10,000, unless they opt for OSS. [vatabout.com]
5.2 Voluntary Registration
- New startups expecting to have low first-year sales but wanting to recover VAT on investments.
- Businesses making only VAT-exempt supplies can sometimes voluntarily register for specific taxable activities (e.g. certain real estate developers can opt to tax sales of property to recover VAT on costs, under specific rules).
- Foreign companies not strictly required to register because all their Danish sales fall under reverse charge might still opt to register if they have significant Danish input VAT to recover (though this is uncommon as they can use refund mechanisms).
5.3 EU OSS/IOSS Schemes
- EU distance sellers can cover Danish consumer sales via OSS after €10k threshold. [vatabout.com]
- Non-EU e-service providers can cover Danish digital services via OSS (no threshold, required for any amount if they want to avoid registration). [vatabout.com]
- Online marketplaces may also be responsible for VAT on certain transactions as “deemed suppliers” under the e-commerce package, which affects how VAT is handled for marketplace sales into Denmark. [vatabout.com]
6. VAT Grouping Rules
- Voluntary: Group registration is not mandatory; businesses choose to form a group if beneficial. [vatcalc.com]
- Eligibility: Generally, only Danish established companies can join a VAT group. All members must be resident (foreign companies’ Danish branches can be included if they have a Danish VAT registration). Non-resident companies cannot be part of a Danish VAT group. [vatcalc.com]
- Linkage requirement: Danish law currently requires a 100% ownership link among group members (one company must directly or indirectly own all the others) for VAT grouping. In practice, typically a parent company and its wholly-owned subsidiaries form a group. (This requirement of full ownership has been subject to EU legal discussion on whether it’s too strict).
- Single taxpayer: The group is treated as a single taxable person. One group VAT number is used for all members. Supplies between members of the group are ignored for VAT (no VAT charged on intercompany transactions within the group). [vatcalc.com]
- Joint liability: All group members are jointly and severally liable for the VAT debts of the group. One designated member (often the parent) acts as the representative to file returns and make payments, but all companies share liability for any unpaid VAT. [vatcalc.com]
- Scope: Only businesses with VATable activities can form a group. If an entity is not VAT-registered (e.g. purely exempt activities) it generally cannot join unless it’s fully owned and included under special rules.
- Administration: Companies are automatically re-assessed every year (typically in February) by the tax authority to confirm they still meet criteria and appropriate VAT reporting groups (this is more relevant for Intrastat grouping thresholds, not the VAT group membership, which remains until changed). [fintua.com]
7. VAT Recovery for Foreign Businesses
- EU businesses (8th Directive refunds): If a company based in another EU member state incurs Danish VAT (for example, on travel expenses, trade fair costs, etc.) and it is not registered for VAT in Denmark, it can reclaim the Danish VAT through an electronic refund process. The EU 2008/9/EC Directive (formerly 8th Directive) allows an EU business to apply via its home country tax portal by September 30 of the following year. The Danish tax authority will refund VAT on allowable business expenses, provided the claimant had no requirement to register in Denmark during that period (i.e. they didn’t perform taxable supplies in Denmark, aside from those subject to reverse charge). [taxation-c….europa.eu] [eurotax.fr], [eurotax.fr]
- Non-EU businesses (13th Directive refunds): Companies from outside the EU can also reclaim Danish VAT on expenses via a paper-based refund claim to the Danish tax authority (Skattestyrelsen). Denmark does not require reciprocity agreements for granting refunds – businesses from any non-EU country can qualify, even if their home country doesn’t refund VAT to Danish firms. Non-EU claims must be submitted by 30 September of the following year with supporting original invoices and a certificate proving the business is registered abroad. The claim must cover at least a 3-month period (or less if it’s the remainder of a calendar year) and meet minimum amounts (DKK 3,000 for claims covering less than a year, or DKK 400 for a full-year claim). [taxation-c….europa.eu] [taxation-c….europa.eu], [taxation-c….europa.eu]
- Eligibility: Whether EU or non-EU, the foreign business must not have had a fixed establishment in Denmark or made taxable supplies there (aside from maybe zero-rated or reverse-charged supplies) during the refund period. If the company was actually VAT registered in Denmark, it cannot use these schemes (it would reclaim via its VAT returns instead). [eurotax.fr], [eurotax.fr]
- Process: EU businesses apply through their own country’s online portal (which forwards the claim to Denmark). Non-EU businesses send a form (in English/Danish/German) to a designated Danish Tax office in Sakskøbing. Claims require details of each expense and copies of invoices. Denmark typically processes duly completed claims within eight months after receipt. [taxation-c….europa.eu]
- Scope of recoverable VAT: Generally, VAT on typical business expenses (e.g. hotel, meals, transport, trade fairs, professional fees) is refundable, except items that would be non-deductible for Danish businesses (see Section 15.1 for input VAT exceptions). For example, Danish rules don’t allow VAT deduction on most entertainment expenses, so a foreign business can’t get a refund for VAT on client dinners or entertainment in Denmark.
- Outcome: If approved, the Danish tax authority issues a refund payment (in DKK or possibly to a foreign bank account in local currency). No interest is paid on refund amounts. If a claim is denied in part or whole, the business can appeal.
8. Fiscal Representative Requirements
- EU-established businesses: Companies established in another EU country do not need a fiscal representative to register for VAT in Denmark. They can register directly with Skattestyrelsen on their own (EU law forbids requiring a fiscal rep for EU traders due to freedom of establishment).
- Non-EU businesses: Denmark does require most non-EU businesses to appoint a Danish-based fiscal representative as a condition of VAT registration. The fiscal rep is typically a Danish resident company or individual, often a tax consultancy, who co-signs the registration. This representative is jointly and severally liable for the VAT obligations of the non-EU business in Denmark. Because of this liability, the representative sometimes requires a bank guarantee or deposit from the foreign trader. [vatcalc.com]
- Exceptions: Denmark exempts certain non-EU countries from the fiscal rep requirement. Notably, businesses from Norway, Iceland, or the UK are not required to have a fiscal representative in Denmark. This exemption is likely due to mutual agreements or the countries’ reliable tax cooperation (Norway and Iceland are EEA members; the UK and Denmark have close VAT cooperation post-Brexit). Companies from these countries can register on their own. All other non-EU countries (e.g. USA, China, India, etc.) must appoint a rep. [vatcalc.com]
- Security deposit: The Danish Tax Agency can ask any foreign business (especially non-EU) for a security deposit upon registration. Commonly, they may require a cash deposit or bank guarantee roughly equal to 3 months’ anticipated VAT liability. This is to safeguard the treasury in case the foreign business fails to pay VAT. The fiscal rep arrangement doesn’t eliminate this – sometimes both a rep and a deposit are needed. [vatcalc.com]
- Role of fiscal rep: The representative’s job is to ensure the foreign business’s compliance – they often handle filing the VAT returns and correspondence with the tax authority on behalf of the business. Since they are jointly liable, they have a strong incentive to ensure VAT gets paid correctly.
- VAT refunds (without registration): As noted in section 7, for VAT refund claims (13th Directive) a fiscal rep is not required, though a foreign business can authorize an agent to handle the claim. The concept of fiscal rep mainly applies to VAT registration and ongoing compliance. [taxation-c….europa.eu]
9. Currency and FX Rules
- Invoicing currency: Businesses in Denmark are allowed to issue invoices in foreign currencies (e.g. EUR, USD) if they wish. However, the VAT amount must be stated in DKK (or additionally in DKK) on the invoice. This ensures the tax amount is clear in the national currency for reporting. [vatcalc.com]
- Conversion of foreign currency: When a transaction’s value is in another currency, the VAT should be calculated by converting to DKK using an official exchange rate. Acceptable rates are typically either the rate published by the National Bank of Denmark (Danmarks Nationalbank) or the rate of the European Central Bank (ECB) on the tax point date. Businesses should be consistent in the source of rates they use. The tax authority’s guidance often allows using the ECB’s reference rates in EUR for simplicity (as many foreign invoices might be in EUR). [vatcalc.com]
- Reporting: In the VAT return, all amounts are reported in DKK. If a company keeps its accounts in another currency, it must convert VAT amounts to kroner for declaration.
- Optional use of EUR: Denmark hasn’t adopted the euro; however, EU VAT legislation allows if an invoice is in EUR, the VAT can be shown in EUR as well, provided the amount is converted to DKK in the accounting. But Danish rules specifically prefer the VAT stated in DKK or at least converted in the records. [vatcalc.com]
- Fluctuations: If an invoice is issued in foreign currency and later paid at a different rate, any difference in DKK due to exchange rate movement is generally not an adjustment to VAT (VAT is based on the value at the time of supply/issuance).
- Display on invoice: A typical approach if billing in, say, EUR to a Danish customer is to show the net in EUR, VAT 25% in DKK (with the rate used) and the total in EUR and/or DKK. Many companies simply choose to invoice Danish customers in DKK to avoid confusion.
- Inter-company or internal conversions: If using a system that posts foreign invoices, ensure the system uses compliant exchange rates to book the VAT in DKK.
10. VAT Law and Legal Framework
- The primary national legislation is the Danish VAT Act (Momsloven) of 1994, as subsequently amended. This law sets out the rules on what is taxable, who is taxable, rates, exemptions, etc., in Denmark. It incorporates provisions to comply with EU directives. [taxsummaries.pwc.com]
- Denmark, as an EU member, is bound by the EU VAT Directive (2006/112/EC), often called the Common VAT System directive. Danish law has been aligned with the EU framework, especially since the major overhaul effective 1 January 2007 when the Sixth VAT Directive was replaced by 2006/112/EC. In areas of inconsistency, EU law takes precedence (the EU directive is effectively supreme over national law in VAT matters). [globalvatc…liance.com] [vatcalc.com]
- Over the years, EU-wide reforms (e.g. the 2010 VAT Package for services, the 2015 digital services rules, 2021 e-commerce package) have been transposed into Danish law. The Danish VAT Act and secondary regulations are updated to reflect these changes. [taxsummaries.pwc.com]
- There is also a VAT Executive Order (Bekendtgørelse) that provides more detailed rules (for example, on invoicing requirements, record-keeping, etc.). As of now, Executive Order on VAT (Momsloven Executive Order) includes detailed provisions such as Article 66 covering e-invoicing (which states e-invoicing is generally not mandatory except for B2G). [globalvatc…liance.com]
- Other relevant laws: The Danish Bookkeeping Act (Bogføringsloven) – particularly the 2022 revision – intersects with VAT in requiring how records and invoices are kept (e.g. digital format, retention rules). Also, customs law and excise laws come into play for import VAT. [vatabout.com]
- Legal hierarchy: The VAT Act (enacted by the Danish Parliament) is the main law. It is supplemented by executive orders and official guidance from the tax authority. The tax authority (Skattestyrelsen) frequently issues binding rulings, guidelines, and interpretations to clarify the application of VAT law in practice. These can be important for edge cases (the exempt categories in §13, for instance, are interpreted through numerous rulings). [taxsummaries.pwc.com]
- Courts: Disputes on VAT are first handled by administrative appeals within the Tax Agency and potentially can be brought to the Danish courts. Because VAT is an EU-harmonized tax, cases may be referred to the European Court of Justice (CJEU) for interpretation of the directive. Denmark has had a number of CJEU cases over the years clarifying points like VAT grouping criteria or specific exemption scopes, which then influence how the law is applied.
11. Tax Authorities
- Skattestyrelsen (Danish Tax Agency) is responsible for VAT registrations, collection of VAT returns/payments, audits, and refunds. Their website (skat.dk) provides information and the self-service portal (TastSelv Erhverv) for businesses. [vatcalc.com]
- The Ministry of Taxation (Skatteministeriet) oversees tax policy and legislation. Skattestyrelsen is under this ministry.
- Within Skattestyrelsen, there are departments specializing in different taxpayer segments (e.g., small businesses, large enterprises) and different taxes (VAT, duties, etc.).
- Contact points: The VAT registration and refund office for foreign businesses is in an office located in Sakskøbing (as indicated in EU docs for non-EU refunds). Domestic businesses typically deal with the regional tax centers or online. [taxation-c….europa.eu]
- Customs (import VAT at the border) is handled by Toldstyrelsen (Customs Agency), but import VAT once accounted for is integrated with the VAT return system if deferred.
- Business portal (Virk): Registrations are done via the Virk.dk business registration portal (connected to the Danish Business Authority for starting businesses), which then liaises with Skattestyrelsen for VAT registration. [skat.dk]
- E-tax for businesses (TastSelv Erhverv): This is the online system where VAT returns are filed and payments tracked. Businesses must use it to file periodic VAT returns and any ESL/Intrastat. The portal also shows the “Tax Account” (Skattekonto) which is a running balance of taxes owed/refunded, including VAT.
- Enforcement: Skattestyrelsen conducts audits and inspections. They have authority to request records, conduct VAT inspections on premises, and assess additional VAT with interest and penalties in cases of errors or fraud.
- Guidance: The tax authority publishes detailed guidance (in Danish) called Den juridiske vejledning covering VAT law interpretation. There is also an English section on skat.dk with basic VAT info for foreign businesses. [skat.dk]
- Appeals: If a business disagrees with a VAT decision, the first appeal goes to the Tax Appeals Agency (Skatteankestyrelsen), then possibly to the National Tax Tribunal or courts.
- For non-residents, there is a dedicated Copenhagen Business Authority office that often coordinates matters like initial registration for foreign companies, but after registration, ongoing compliance is with Skattestyrelsen. [vatcalc.com]
12. Scope of VAT
- Supplies of goods or services in Denmark: If a taxable person (business) supplies goods or services and the place of supply is deemed to be Denmark, that transaction is within the scope of Danish VAT. “Supply” is any transaction where something is provided in return for payment (including barter or self-supply). [vatcalc.com]
- Intra-Community acquisition of goods: Goods brought into Denmark from another EU member state by a business or VAT-liable entity are taxed in Denmark as an intra-EU acquisition (at 25%), to avoid tax evasion on cross-border purchases. Typically, the buyer self-accounts for Danish VAT. (Private individuals buying goods from the EU are an exception – they pay foreign VAT unless above distance selling threshold). [vatcalc.com]
- Import of goods from outside the EU: When goods from non-EU countries enter Denmark, import VAT is due (normally at 25%) as they clear customs. This equalizes imported goods with domestic goods. The importer (if a business) pays or accounts for this import VAT. [taxsummaries.pwc.com]
- Receipt of services from abroad (Reverse charge): If a Danish business or organization receives services from a foreign supplier (e.g. consulting from a US firm), and the service’s place of supply is Denmark under general rules, then the Danish recipient must reverse-charge VAT (i.e. self-account for Danish VAT). This effectively brings most B2B services from foreign suppliers into the VAT net. [taxsummaries.pwc.com]
- “Deemed supplies”: Denmark taxes certain transactions that are not sales in the normal sense but are treated as supplies to ensure neutrality. For example, private use of business assets (like if a company car is used privately), giving away business goods (above certain low value), or self-supply of services (like a business constructing an asset for itself) can be treated as taxable supplies by the VAT Act, to prevent avoidance. [globalvatc…liance.com]
- Other: The law also covers special scenarios like distance sales to consumers (which, post-2021, basically means if a foreign seller opts out of OSS, those sales into DK are in scope and require registration). Also call-off stock movements and consignment stocks, if title passes in Denmark, are regarded as local supplies when the stock is called off.
13. Time of Supply Rules
13.1 Goods
- If an invoice is issued or payment received before delivery, then VAT can become due at that earlier point to the extent invoiced/paid (for example, if you invoice a customer and deliver later, the invoice date triggers VAT; or if you take a prepayment, VAT on that amount is due when received). [vatcalc.com]
- Danish rules essentially say an invoice should be issued at the time of supply or very shortly thereafter, which aligns with making the tax point at delivery/invoicing. [vatcalc.com]
- If goods are shipped, the time of supply is when shipment or dispatch to the buyer begins (assuming that’s when transfer of risk occurs).
- There is a special rule for goods supplied on approval or consignment (see 13.5).
13.2 Services
13.3 Continuous Services
- If services are provided continuously over a period (e.g. a 12-month consulting contract with no periodic invoicing), Denmark follows the EU rule that there must be a tax point at least every 12 months. In practice, you should issue an invoice at least once a year for ongoing services, triggering VAT then. [vatcalc.com]
- Typically, for recurring services (like subscriptions, leasing, etc.), the tax point is when each billing period ends if not invoiced before. For example, if you have a quarterly service with no prior invoice, at the end of the quarter the VAT is due then. [vatcalc.com]
- Continuous supply of goods (like ongoing pipeline gas or electricity) is treated similarly – monthly or periodic tax points.
- The Danish guideline as per the VAT order: for continuous supplies of services that span tax periods, the tax point is at the end of each VAT return period (month/quarter) in which the service is provided, if no invoice has yet been issued. This ensures VAT is accounted for regularly even if billing is delayed. [vatcalc.com]
- For rentals or leasing, often the time of supply is each due date or rental period.
13.4 Imports
- If you import goods through Danish customs, import VAT is due at the time of importation (usually concurrently with any customs duty payment). [vatcalc.com]
- The import VAT can be paid immediately to customs or, if the importer is registered for postponed accounting, declared in the next VAT return (see section 15.6).
- If goods are placed under a customs suspension regime (like a bonded warehouse or transit), the VAT point is when they are released from that regime into free circulation.
- For imports, the “invoice” concept is less relevant; it’s the act of importation that triggers VAT.
- If an importer has deferment, technically the tax point might still be import date, but payment is shifted to the return.
13.5 Goods on Approval/Return
- Danish rules allow the tax point to occur when the customer confirms the purchase of the goods or when the approval period expires and the goods haven’t been returned. In other words, VAT is due only on the goods actually sold (not on those returned).
- If goods are shipped to a customer “on approval” with an agreement that they may be returned within, say, 30 days, then the VAT becomes due when the customer indicates acceptance (purchase) of the goods, or if they keep the goods beyond the 30 days (tacit acceptance).
- If the customer returns the goods within the allowed period, then that supply effectively never happened for VAT (no tax due).
- The Danish VAT Act likely requires an invoice when the sale is confirmed. If an invoice was issued initially for the full amount, it might need to be canceled or credited for any returns.
- In absence of specific national deviations, one can analogize that either the time of supply is the earlier of explicit purchase or a set time limit. Otherwise, if goods are simply taken on consignment without a clear time limit, a 12-month rule might apply similar to continuous supplies.
14. VAT Invoicing Requirements
14.1 Invoice Issuance Deadlines
- For domestic B2B sales, while no explicit number-of-days deadline is in the law, it is expected that an invoice is issued immediately at delivery or within a reasonable time (usually no later than the 15th of the following month to meet EU requirements for cross-border supplies). [vatcalc.com]
- For intra-Community supplies (B2B sales to EU customers), EU rules mandate the invoice be issued by the 15th day of the month following the month of supply. Denmark follows this: if you sold goods on March 20 to a VAT-registered buyer in Germany, you must invoice by April 15. [vatcalc.com]
- For domestic B2C sales, businesses like retailers issues receipts on the spot. Small cash sales have simplified rules (see 14.4), but generally an invoice/receipt is at point of sale.
- If a payment (prepayment) is received before the goods/service is delivered, an invoice for that advance should be issued at time of payment (and VAT accounted at that time).
- Services completed – invoice upon completion or periodic if ongoing.
- There is no specific statutory “X days after supply” rule in Denmark beyond the EU cross-border requirement. But as a best practice, invoicing without undue delay is required. If an invoice is not issued timely, it could jeopardize the customer’s right to deduct VAT and risks non-compliance for the supplier.
- OSS transactions: If a sale is reported under the OSS (One-Stop Shop) scheme (distance sales or digital services), no Danish VAT invoice is required to be issued to the customer. In fact, the EU OSS rules do not require a tax invoice for those B2C sales. So an e-commerce seller using OSS might not issue a formal VAT invoice (though they usually still send an order confirmation/receipt to the customer). [vatcalc.com]
14.2 Required Contents
- Invoice date (issue date).
- Sequential invoice number that uniquely identifies the invoice.
- Supplier’s name, address, and Danish VAT number. [vatcalc.com]
- Customer’s name and address. If the customer is a business in another EU country or a Danish business receiving a reverse-charged supply, their VAT number must also be stated. [vatcalc.com]
- Description of goods or services supplied, and the quantity or extent. (Clear, commercial description so it’s identifiable). [vatcalc.com]
- Date of supply of the goods or services, if different from the invoice date (especially if invoicing after the supply). [vatcalc.com]
- Net amount (taxable amount) for each rate or exemption, price per unit (excluding VAT) and any discounts (if not included in unit price).
- Applied VAT rate for each line (e.g. 25% or 0%).
- VAT amount payable, in DKK (even if the rest of invoice is in foreign currency, the VAT should be shown in DKK or accompanied by a DKK conversion). [vatcalc.com]
- If an exemption or reverse charge applies, a reference to the applicable provision. For example, for an intra-EU supply one might note “0% VAT – intra-Community supply, VAT Act §34” or for reverse charge “Reverse charge – VAT payable by recipient (Momsloven §19)”.
- If it’s a credit note or invoice correction, it should reference the original invoice series.
- Other helpful info: payment terms, supplier’s bank details – though not legally required by VAT law, they are common business practice.
- Reverse charge: must specifically state “Reverse charge” and include the customer VAT number. [vatcalc.com]
- Margin scheme (if used for second-hand goods, etc.): must mention e.g. “Brugtmoms – margin scheme, VAT not deductible”.
- Currency: If amounts are in a foreign currency, showing the exchange rate or DKK equivalent for the VAT is required (ensuring tax is clear in DKK). [vatcalc.com]
- E-invoices: Same content requirements as paper invoices.
14.3 E-invoicing and Digital Signature Rules
- B2G e-invoicing: Denmark was an early adopter of mandatory e-invoicing for sales to the public sector. Since 2011, business-to-government invoices must be sent electronically in the NemHandel/OIOUBL format. So if you supply a Danish government entity, you must issue an e-invoice through the government system (paper is not accepted). [globalvatc…liance.com]
- B2B/B2C: For now, there is no general mandate for electronic invoicing between private businesses or to consumers. Paper or PDF invoices are acceptable, as long as they contain the required info. [vatabout.com]
- Digital signature: Denmark does not require digital signatures or advanced electronic signatures on e-invoices. Authenticity and integrity of invoices must be ensured, but this can be achieved by business controls or any accepted means (digital signature is one way, but not compulsory).
- Electronic storage: Electronic invoices must be stored electronically (see 14.6). The authenticity (that the invoice is from who it says) and integrity (no alteration) should be guaranteed. Many businesses use PDF invoices sent by email, which is common and acceptable without a formal digital signature, relying on trust and internal controls.
- New Digital Bookkeeping Act: Under new rules, businesses will need to have systems capable of e-invoicing. Starting 1 January 2026, all VAT-registered businesses (including foreign ones crossing threshold) will be required to use a digital bookkeeping system that can send and receive electronic invoices and produce SAF-T data. This is part of Denmark’s move towards digital compliance. So while e-invoicing itself isn’t yet mandated for each transaction between private entities, companies must be ready and equipped for it. [vatabout.com], [vatabout.com]
- Standards: The NemHandel system uses UBL XML format. The European standard e-invoice (EN 16931) is also recognized. Many Danish companies already voluntarily exchange e-invoices via networks like PEPPOL.
- Summary: So currently, e-invoicing is optional (except for government sales). If used, no specific digital signature is mandated, but the invoice must remain unaltered and accessible. The trend is towards more digital invoices with the Bookkeeping Act requiring readiness for e-invoicing and standard digital record formats by 2024–2026. [globalvatc…liance.com] [fintua.com], [vatabout.com]
14.4 Simplified Invoices
- For retail sales and other minor transactions not exceeding DKK 3,000 (approx €400), a simplified receipt can be issued instead of a full VAT invoice. A simplified invoice/receipt does not need the buyer’s name/address or their VAT number. It must include at least: date, identification of seller, what was sold, total amount with VAT, and maybe VAT rate or a statement that VAT is included at 25%. [vatcalc.com]
- Simplified receipts are common in shops, restaurants, etc. If the customer is a business and later needs a full invoice (maybe they made a large purchase > DKK 3,000 or simply need it), the seller should provide a full invoice on request.
- The threshold in Denmark is DKK 3,000 for being allowed to omit certain elements. Above that, a full invoice is required. [vatcalc.com]
- There’s a special note: if a service exceeds DKK 5,000, a full VAT invoice is always required, even in a B2C context. This prevents high-value services from being invoiced on simplified till receipts. [vatcalc.com]
- For example, a taxi ride or a small shop sale will have a receipt listing gross amount, VAT included, etc., and that suffices.
- Till receipts for cash sales are accepted as simplified invoices as long as they have the necessary info and unique sequential numbering from the cash register.
- In any case, the simplified invoice must allow the tax authorities to compute the VAT. Usually that means showing either the VAT amount or stating “including 25% VAT” so that one can work it out.
- Credit card slips alone are not invoices; the receipt from the seller is what counts.
14.5 Self-Billing
- There must be a mutual written agreement between the supplier and customer to use self-billing. [vatcalc.com]
- The agreement should ensure the supplier accepts each invoice that the customer issues. In practice, the supplier often formally or tacitly approves the invoices raised by the customer.
- Each self-billed invoice must still meet all the standard content requirements (it will have the supplier’s VAT number, etc., but is issued by the customer).
- Self-billing is common in industries with ongoing relationships, like supermarkets self-billing their small vendors.
- The supplier remains responsible for the VAT, so they must ensure the invoices are correct.
- If a self-billing agreement ends or if the supplier’s VAT number changes, the self-biller must be informed.
- Denmark follows the EU rules on this: acceptance of each invoice by the supplier can even be by prior agreement that all will be deemed accepted unless contested.
14.6 Retention Period
- The 5-year retention applies to all accounting material, including invoices (paper or electronic), accounting records, and relevant correspondence.
- Records must be kept in a readily accessible manner. If stored electronically, they should remain readable for 5 years. Software or formats should be maintained so data can be retrieved.
- Location of storage: Generally, records should be stored in Denmark. Storing electronically abroad is allowed if certain conditions are met (e.g. notifying the tax authority). Denmark permits electronic records to be kept outside Denmark, but possibly with an obligation to provide on request quickly. [vatcalc.com]
- Some specific records (like documents related to immovable property) might have longer retention (10 years) if related to the capital goods adjustment period.
- As of new bookkeeping rules, electronic storage will become the norm, but the 5-year period remains.
- Businesses that fail to keep records for 5 years can face penalties. Also, inability to produce an invoice could jeopardize input VAT deduction claims, etc.
14.7 Invoice Correction Methods
- A credit note (kreditnota) should be issued to reduce the invoiced amount or cancel it. It must cross-reference the original invoice (by number and date) and include negative amounts or the amount to adjust. The credit note effectively serves to adjust the VAT declared. [vatcalc.com]
- Similarly, a debit note would be issued if under-billed initially and you need to charge more VAT (though usually one would just issue a new invoice for additional charge).
- The credit note should contain the same info as an invoice, but with negative values for the adjustment.
- Once issued, the supplier will adjust its VAT output in the return for the period of the credit note (or current period if allowed). Historically, Denmark didn’t allow VAT refunds to suppliers for overcharged VAT unless a corrected invoice (credit note) was issued and the customer reimbursed, but guidance in 2025 updated some approach on incorrectly charged VAT. [vatcalc.com]
- The Danish Tax Agency updated guidance in May 2025 regarding corrections of incorrectly charged VAT. Essentially, it clarified that to get a refund of VAT that was wrongly charged on an invoice, one must correct the invoice (issue a credit note) and either not collect that VAT or refund it to the customer. This aligns with the requirement to prevent unjust enrichment. [vatcalc.com]
- If an invoice is simply canceled in full, a credit note for the full amount (bringing net to zero) is the way to do it.
- Mistakes like typo in address usually don’t need a credit note; those can be corrected administratively as they don’t affect tax. But any change affecting the amount or VAT requires an adjustment document.
- The phrase “must clearly reference the original invoice” is key – Danish books need to show the link so auditors can trace from original invoice to adjustment. [vatcalc.com]
- If a business discovers it forgot to invoice VAT earlier, it should issue a supplementary invoice (debit note) now for that VAT (within the statute of limitations).
- All credit/debit notes must also be numbered and accounted for.
15. Compliance and Deductions
15.1 Right to Deduct Input VAT and Key Exceptions
- Non-business (private) use: No deduction for VAT on purchases that are for private or non-business use. If an item is used partly for business and partly private, only the business-use portion of VAT is deductible.
- Entertainment expenses: VAT on business entertainment (client meals, entertainment events) is not deductible in Denmark. This includes entertainment of customers or other business contacts. (However, a portion of hotel and restaurant expenses for business travel is deductible – see below). [vatcalc.com]
- Travel, meals for employees: VAT on restaurant meals is generally not deductible except when traveling. Denmark’s rules: meals and lodging for employees on business travel can be deducted (they are not considered “entertainment” but travel expenses). But purely taking a client to dinner is entertainment (non-deductible).
- Business gifts: VAT on gifts to customers or others is usually not deductible, except for low-value promotional items. In Denmark, the limit for gifts is very low – only gifts of value up to DKK 100 are deductible. Anything above that, no input VAT recovery. [vatcalc.com]
- Passenger cars: Input VAT on the purchase, lease, and running costs of passenger vehicles (cars) is generally not deductible if the car is available for personal use. If a car is 100% business-used with no private use, deduction might be possible, but that’s rare (company cars in Denmark are usually considered to have some private use). There may be a 0% deduction on purchase and a partial on lease (in some countries 50% on car lease; Denmark historically had no deduction on cars unless taxi or resale). [vatcalc.com]
- Fuel for cars: Similarly, VAT on fuel for passenger cars often not deductible if the car itself isn’t deductible. If a car is partially used for business, you might proportionally deduct fuel, but Denmark likely simplifies by blocking most.
- Employee benefits: VAT on free perks to staff (like free housing, free meals at canteen beyond a token price) is often not deductible because it’s not a cost of making taxable supplies.
- Home telephone/internet: Denmark specifically mentions 50% of VAT on telephone line for home use is blocked, unless separate business line. So if a business reimburses an employee for a home phone used half the time for work, then only half the VAT can be deducted. [vatcalc.com]
- Housing/accommodation for employees: VAT on renting a house or flat for employees (e.g. expat housing) is not deductible, as it’s considered a personal expense (with some exceptions if it’s temporary business travel lodging).
- Finance/insurance purchases: If a business makes exempt supplies (like a bank), it cannot deduct input VAT related to those exempt activities. Companies with mixed supplies must do a pro-rata allocation. If a company has partial exemption, they can only reclaim the fraction of VAT corresponding to taxable turnover (with adjustments at year-end).
- No deduction on VAT that wasn’t correctly invoiced: If VAT is not properly invoiced (e.g. invoice to wrong name, or supplier not actually charging VAT properly), deduction can be denied. Also if supplier charged VAT erroneously (like on an exempt supply), the buyer technically cannot deduct that until corrected.
15.2 Call-Off Stock Arrangements
- When an EU supplier transfers its own goods to Denmark to be held as stock for a known intended buyer, no immediate VAT is due on arrival. It is not treated as a taxable supply or acquisition at that point, provided certain conditions are met (the customer will take them within 12 months, etc.). [vatcalc.com]
- The supplier does not have to register in Denmark under this arrangement. Instead, when the customer actually takes title to the goods (calls them off), the supplier does a zero-rated intra-Community supply from their country to the customer, and the customer does an intra-Community acquisition in Denmark (accounting for Danish VAT). [vatcalc.com]
- Essentially, the VAT event (tax point) is deferred until the final call-off, and it’s handled as EU sale/purchase at that moment.
- Conditions: The goods must be shipped to Denmark with the customer known at dispatch, the customer is VAT-registered in Denmark, and the goods are taken within 12 months. Both parties must keep a ledger of these movements. If 12 months pass without call-off, or customer changes, then a deemed supply could occur requiring the foreign supplier to register. [vatcalc.com]
- Domestic call-off (supplier and stock in Denmark): that’s just consignment stock in-country and wouldn’t involve the EU simplification, but domestically the supplier just hasn’t made a supply until withdrawal (no special rule needed aside from general time of supply on approval).
- This simplification is one of the “Quick Fixes” implemented EU-wide. Denmark implemented it effective 1 Jan 2020 to harmonize call-off stock treatment. [vatcalc.com]
- Before 2020, a foreign supplier sending goods to a Danish warehouse usually had to register for VAT and report a transfer/acquisition to itself then local supply. The new rule avoids that compliance burden.
15.3 Domestic and Cross-Border Reverse Charge Mechanisms
- Cross-border B2B services: Under EU rules, most services supplied from a foreign business to a Danish business fall under the general B2B reverse charge (place of supply in DK, but supplier is abroad so customer must account). This covers consulting, advertising, electronic services, etc., received from abroad. The Danish business must self-account 25% VAT on its VAT return (and simultaneously deduct it if allowable, making it neutral). [taxsummaries.pwc.com]
- Intra-Community acquisitions of goods: When a Danish VAT-registered business buys goods from another EU country, it does a reverse charge (called acquisition VAT) – essentially the buyer charges itself 25% Danish VAT on the purchase and (usually) deducts it. This is how intra-EU goods purchases are taxed. [taxsummaries.pwc.com]
- Non-established supplier in Denmark B2B: If a foreign supplier without Danish establishment provides goods or certain services and is not registered in Denmark, often the reverse charge applies, meaning the Danish business customer must account for the VAT. In fact, Danish law has a provision that if a foreign company sells goods in Denmark to a VAT-registered customer, and the foreign company isn’t registered, the customer must reverse charge. This avoids forcing foreign suppliers to register if their only customers are VAT-registered. (One example: a foreign company installs equipment in a Danish factory for a Danish VAT-registered business – Danish law allows reverse charge so the foreign company might avoid registration.) [vatcalc.com]
- Domestic reverse charges (anti-fraud sectors): Denmark has implemented domestic reverse charge for certain high-risk goods and services to combat VAT fraud. These include:
- Supply of certain electronics: The sale of mobile phones, smartphones, tablets, laptops, and gaming consoles in bulk between businesses is under reverse charge in Denmark. (Likely when sold B2B and both are VAT-registered, to prevent carousel fraud in electronics.) [vatcalc.com]
- Supplies of gas, electricity, heating, cooling energy to resellers: reverse charge applies so that traders in these energy products don’t charge VAT to each other. [vatcalc.com]
- Supply of scrap and waste materials (metal scrap, recyclable materials) – typically reverse-charged to avoid missing trader fraud. [vatcalc.com]
- CO2 emission allowances – trade in carbon credits is reverse charged in Denmark, as in many EU states. [vatcalc.com]
- Certain construction works? Some countries reverse charge certain building services; Denmark historically did not for general construction, but note:
- Telecommunications services (wholesale): As of 1 Jan 2024, Denmark introduced a domestic reverse charge on B2B supplies of telecommunication services (like phone airtime wholesale). This is an anti-fraud measure. [vatcalc.com]
- Possibly precious metals or investment gold transactions have special rules too (investment gold is VAT-exempt by directive, but i.e. if not exempt, reverse charge might apply).
- The list given explicitly in the vatcalc summary for domestic RC includes: natural gas and electricity; scrap metals; mobile phones; game consoles, laptops, tablets; CO2 quotas; telephony services (from 2024). [vatcalc.com]
- In all these cases, the supplier does not charge VAT on the invoice, instead indicating “reverse charge.” The customer accounts for VAT on their return (and deducts it if entitled).
- Construction: Denmark does not have a broad reverse charge for construction (some countries do for subcontractors). However, there might be a specific reverse charge if a foreign sub-contractor without a DK VAT number works for a VAT-registered contractor – then it would fall under the non-established supplier rule, effectively a reverse charge by the Danish customer.
- All B2B services from foreign suppliers. [taxsummaries.pwc.com]
- EU goods acquisitions. [taxsummaries.pwc.com]
- Sales by foreign suppliers to VAT-registered buyers in DK (to avoid foreign reg). [vatcalc.com]
- Fraud-prone domestic sectors: electronics, scrap metal, CO2 permits, gas/electricity trading, telecom wholesale, etc.. [vatcalc.com]
- Effectively shifting VAT accounting to the buyer in those cases.
15.4 Treatment of Cash Discounts
- If at the time of sale, a cash discount is offered (e.g. “2% off if paid within 10 days”), the VAT can be calculated on the actual amount paid. There are two ways to handle:
- Invoice shows full amount and discount terms: Often the invoice will list the full amount and note e.g. “2% discount if paid by X date”. In this case, the supplier must initially account for VAT on the full amount. If the customer takes the discount (pays early and short pays 2%), then the supplier needs to adjust (issue a credit note for the discount portion’s VAT). [vatcalc.com]
- Alternatively, some suppliers invoice the discounted amount upfront, but that’s rare because the customer might not pay early.
- Danish guidance: the discount should be deducted from the taxable base if actually taken. Initially, VAT is on the full price; when early payment is made taking the discount, the supplier issues a credit note for the discount amount and corresponding VAT. The supplier can then reduce output VAT by that amount. [vatcalc.com]
- If the discount is not taken (customer pays late or full amount), then no adjustment is needed – VAT on full amount stands.
- Trade discounts (where the invoice already nets it out) just reduce the price immediately, so VAT is on net.
- Settlement discounts (post-sale) are treated similarly: adjust via credit note so that VAT is only on the amount actually received.
- Note: if the supplier doesn’t issue a credit and leaves it, technically they have overpaid VAT (since they only got 98% of price but paid VAT as if 100%). They should adjust, otherwise the customer has over-deducted as well if they deducted on full.
- For simplicity, some businesses might always account as if discount will be taken, but if it’s not, then they’d issue a debit note for the difference. Either approach is allowed as long as final VAT matches final price paid.
15.5 Bad Debt Relief Conditions
- The debt must be truly uncollectible – typically meaning the debtor is insolvent, bankrupt, or the creditor has taken all reasonable steps to collect without success. [vatcalc.com]
- There is usually a time period after which a debt can be considered bad. For smaller amounts or any, Denmark’s practice is that if it’s clearly uncollectible (e.g. bankruptcy confirmed), relief can be claimed. If not, guidance suggests typically at least 6 months or more of non-payment and evidence of attempts to collect.
- For larger debts (over DKK 3,000), Denmark requires proof like the customer’s bankruptcy, liquidation, or a court declaration that the debt cannot be recovered. Some formal evidence that the debt is worthless. [vatcalc.com]
- If the debt is under DKK 3,000, possibly a more straightforward write-off in accounts might suffice (the threshold suggests above DKK 3,000 needs formal proof for relief). [vatcalc.com]
- The supplier must have written off the amount in its accounts as a bad debt. That is, it’s removed from outstanding receivables and recognized as a loss. [vatcalc.com]
- The relief is claimed by adjusting the VAT in the VAT return (output VAT is reduced by the amount that was originally paid on that bad invoice). Typically on the return for the period in which the debt is written off (or later if discovered). [vatcalc.com]
- If by chance the debt is later paid after taking relief, the supplier must then declare that VAT.
- Example: You sold goods for DKK 10,000 + VAT 2,500, declared the 2,500 to Skat, but customer went bankrupt and you only got a few hundred via the estate, remainder is uncollectible. You can claim back the VAT on the unpaid portion (say DKK 2,300).
- Exclusions: If you factored the receivable and got paid by a factor, you have no bad debt. Or if you didn’t attempt collection at all, might be challenged. Also bad debt relief might not apply if you sold to a related party under unusual circumstances.
15.6 Import VAT Deferment Schemes
- Deferred accounting (VAT loan scheme): Denmark allows companies to defer import VAT by not paying it at the border, instead declaring it on their periodic VAT return (much like how intra-EU acquisitions are handled). This is often called postponed accounting. To use this, an importer usually needs to be approved or have a general VAT deferment guarantee. [vatcalc.com]
- Historically, Denmark required importers to provide a bank guarantee or participate in a government warranty scheme to defer VAT. They call it the “Arrears account” or using the Skattekonto for VAT rather than paying at customs. [vatcalc.com]
- Under this scheme, when goods are imported, no actual VAT is paid at that moment; instead, the importer simply includes the import VAT in their next VAT return as both output (due) and input (deductible) if they’re entitled, effectively nullifying the cash outlay. [vatcalc.com]
- Guarantee requirement: To obtain this deferment, a business might need to provide a security (bank guarantee) unless exempt. The text says “through government’s warranty regime, or providing a bank guarantee”. [vatcalc.com]
- There is also a specific import exemption for goods re-exported: If goods are imported into Denmark and then dispatched to another EU country within 30 days, the import can be exempted from VAT. This is to facilitate transit trade. But the importer must have a Danish VAT number and inform the Danish tax office in advance, including any fiscal rep’s details for non-EU importers. Essentially, if you import and immediately (within a month) make an intra-EU supply, you may not have to pay import VAT at all. [vatcalc.com]
- Simplified clearance: Denmark is integrated in EU customs systems so usually import VAT can be accounted via monthly settlement if authorized.
- For non-established importers: They would need a fiscal rep to use these schemes and likely must provide security.
- Goal: These deferment schemes improve cash flow – you don’t pay VAT up front and then wait to reclaim it; instead, you offset it in the return directly (if fully deductible, it cancels out).
15.7 VAT Warehousing
- Typically, goods like non-EU goods under customs suspension, or certain EU goods (like investment gold, certain works of art, etc. as allowed by directive) can be placed in a VAT warehouse.
- While goods are in the authorized warehouse, sales of those goods can be made VAT-free (zero-rated). VAT only becomes due when goods are removed for final consumption in Denmark. [vatcalc.com]
- This is particularly useful for commodities trading (metals, etc.) or high-value goods, where multiple transactions can occur on paper while the goods sit in a warehouse, and no VAT is due on those interim trades.
- Denmark requires a Danish VAT number to operate or use a VAT warehouse facility. The warehouse has to be authorized by the authorities. [vatcalc.com]
- Imported goods can go into a VAT warehouse after clearing customs. Once in, the import VAT can be deferred until release.
- Transactions within the warehouse: normally zero-rated (with right to deduct) for VAT. [vatcalc.com]
- When goods leave the warehouse to a Danish buyer for use, that’s when VAT is charged. If they are exported out of EU from the warehouse, then they remain zero-rated as exports.
- The scheme covers limited categories (the EU law enumerates which goods can qualify).
- VAT warehousing is not as widely used in DK as in some countries, but it exists for specific sectors (like bulk wine, alcohol under duty suspension which is separate but similar concept with excise warehouses).
- Example: Company A buys a large batch of electronics and stores them in a VAT warehouse. It sells to Company B while still in warehouse – no VAT on that sale. B then withdraws some items to bring to market; at that point B pays VAT on those to the tax authority (output tax when selling out of warehouse).
- This prevents large VAT outlays for companies that trade goods internationally or in transit.
15.8 Supply-and-Install Rules
- If a non-resident supplier sells goods and also provides installation services for a business customer in Denmark, that transaction can often fall under the reverse charge mechanism, meaning the Danish business is responsible for the VAT. The foreign supplier would not need to register for Danish VAT, as long as the customer is a VAT-registered business and both agree to apply reverse charge. [vatcalc.com]
- The vatcalc text says: “Non-resident providers of install of goods services should use the reverse charge (shifting VAT responsibilities to their business customers) and do not need to VAT register.” This implies that rather than treating it as a goods supply that forces the supplier to register and charge VAT, Denmark allows it to be handled as a service where the Danish customer self-accounts. [vatcalc.com]
- Essentially, supply-and-install for B2B is simplified by making it the customer’s liability to report the VAT. The foreign supplier invoices without Danish VAT.
- If the customer is not VAT registered (B2C scenario, or say an exempt organization), then this simplification might not apply – the foreign supplier would likely have to register and charge VAT on the goods+installation, because reverse charge can’t be used on B2C.
- There may be thresholds or definitions: Typically if installation is substantial (like creating immovable property), it might always result in domestic VAT. But many countries allow if installation is incidental or done for a business, the reverse charge can apply as import of service.
- Example: A German company sells a machine and sends technicians to install it in a Danish factory. The Danish factory is VAT-registered. The deal can be invoiced with reverse charge, and the Danish factory will account for 25% VAT on the total. The German company thus avoids needing a DK VAT number.
- If the same German company installed a kitchen in a private Danish home (B2C), that would likely require Danish VAT registration because reverse charge cannot be used (the homeowner can’t self-account).
- So the rule is primarily to relieve foreign suppliers from registration when serving VAT-registered Danish businesses for goods with installation.
- Note: Installation services related to immovable property (construction) often are taxed where property is, which is Denmark, but here the reverse charge is effectively being used to collect that VAT via the Danish customer.
15.9 Use-and-Enjoyment Provisions
- Under EU law, member states may override default place-of-supply rules for certain services (like hiring of goods, telecom, electronically supplied, broadcasting, transport etc.) to tax them where they are used if otherwise they’d escape tax.
- Denmark’s rules: For services provided by a non-EU business to a Danish consumer, if those services are consumed or used in Denmark, Denmark may say VAT is due in Denmark (even if normally outside scope). The vatcalc snippet gives a list of services where non-EU businesses providing to B2C in Denmark trigger Danish VAT due to use-and-enjoyment. These include: [vatcalc.com]
- Electronic services (digital products, downloads) provided to Danish private individuals by a non-EU supplier – indeed since 2015, EU requires those to be taxed in customer’s country (which is done via OSS now, but conceptually it’s use-and-enjoyment).
- Telecommunications and broadcasting services to Danish consumers by non-EU suppliers – similarly taxed in DK. [vatcalc.com]
- IP-related services (likely royalties, licenses? – though often B2C is rare, but possibly things like software licensing).
- Consulting services to private individuals? Typically consulting is B2B focus, but maybe they mean if a US consultant advises a Danish individual (it would normally be outside EU’s scope since supplier outside EU and B2C general rule is where supplier is – which is outside EU, no VAT – but Denmark might impose local VAT via use/enjoyment).
- Financial services: Possibly certain financial or insurance services if provided to consumers? But those are usually exempt if domestic. Could be if they are exempt normally domestically, they might not tax foreign ones either. Or maybe financial services to B2C from outside could be taxed to not advantage foreign providers? This one unclear; the list says “financial services”, but those are exempt when local, so maybe they mean if a non-EU charges a Danish consumer for a normally exempt service, Denmark can’t impose VAT because it’s exempt normally. Might be an error in context. [vatcalc.com]
- Supply of staff: If a foreign company supplies temporary staff or personnel services to a Danish consumer? That scenario is odd (consumers usually don’t buy manning services). Perhaps if to a Danish business it’s normal B2B RC, so B2C of staff supply maybe yes if any.
- Natural gas and electricity to consumers by non-EU providers – but practically gas/electric to consumers comes through local utility, not from abroad directly. Possibly meaning if a yacht refuels gas? Seems more B2B again.
- Advertising services to private recipients? Unlikely that qualifies as B2C common scenario.
- It’s possible that list in vatcalc is inclusive of things that might also have other place rules. They likely enumerated categories allowed by Articles 58 and 59 of the VAT Directive for use-and-enjoyment:
- Electronically supplied services, telecom, broadcasting – yes (Denmark likely taxes them where used if outside supplier).
- Hiring of means of transport – often use/enjoyment rules apply (like hiring a car to a consumer may be taxed where used).
- Certain cultural, entertainment services possibly – but those usually taxed where physically carried out.
- The list including consulting, financial, etc. suggests Denmark might have broad use/enjoyment where if a non-EU person provides any service listed in VAT Directive Article 59 (which includes consulting, legal, banking) to a consumer in DK, then place is shifted to DK. This prevents avoidance by, say, a consumer going to a non-EU provider of such services VAT-free while local providers would charge VAT if such services are taxable (though consulting is not usually taxable B2C by local because base rule: B2C where supplier is, which if local means taxed; so a DK consumer can go to a non-EU consultant and pay no VAT, so Denmark might choose to tax that under use/enjoyment).
- However, some listed (financial services) are exempt if done by local banks, so taxing foreign provider would create inequality. Possibly they meant “financial services that are normally taxable (like advisory)”.
- Additionally, Denmark might use use/enjoyment to ensure certain services to businesses are not taxed in DK if they are actually used abroad (less common).
- On the flip side, if a Danish business provides certain services that would normally be taxed in DK but they are effectively used outside EU, Denmark can zero-rate them. E.g. hiring of equipment to an EU customer might be taxed by default, but if equipment is used outside EU, directive allows not taxing it. Not sure if DK implemented that side.
15.10 Capital Goods Adjustment Period
- For movable tangible assets (equipment, machinery, vehicles, etc.), the adjustment period is 5 years. This means if a business buys a machine and deducts full VAT, and then within 5 years the usage changes (e.g. machine now used partly for exempt activities or sold), they may need to adjust (pay back) a portion of VAT for the remaining period. Conversely, if initially partially deducted and later used fully for taxable, they can reclaim more. [vatcalc.com]
- For immovable property (real estate), the adjustment period is 10 years. If a company constructs or buys a building and deducts VAT (like on a new building, which in Denmark can have VAT if opted or it’s a new build sale), then their use of that building is monitored over 10 years. Changes in use (taxable vs exempt use) during that window trigger proportional adjustments of the originally deducted VAT. [vatcalc.com]
- The adjustment is typically 1/5 or 1/10 of the VAT per year remaining of the period whenever a change occurs.
- Example: Company builds a new office in 2020, VAT on costs 1m DKK, fully deducted because intended for taxable rental. If in 2023 (year 4) they start using 50% for exempt education activities, they must adjust 50% of remaining period’s worth. That would be 50% of (1m * (7/10) since 3 years used, 7 left) or something accordingly.
- If they sell a capital asset during the adjustment period, they must adjust in the year of sale as well. If sold to someone who will use it for taxable, often no payback needed (transfer with adjustment maybe).
- Inventory is not considered capital goods (immediate deduction, no multi-year adjustment).
- Vehicles/buildings: It’s noteworthy many vehicles’ VAT is not deductible to start with (like passenger cars), so adjustment moot for them.
- This system ensures fairness: the initial VAT deduction reflects actual use over time. Denmark’s periods (5 and 10) match the standard EU minimums.
16. VAT Recovery for Non-Residents
16.1 EU 8th Directive Refunds
- An EU business (established in another EU country, not registered in Denmark) that paid Danish VAT (for example, on hotel bills, conference fees, local purchases) can apply for a Danish VAT refund via their home country’s electronic portal. [eurotax.fr]
- Conditions: During the refund period (usually a calendar year or shorter), the business must not have had a place of business in Denmark and must not have made any taxable supplies in Denmark (except very limited ones like reverse charge services or certain zero-rated transport). If they have a Danish VAT registration, they can’t use this scheme. [eurotax.fr]
- Procedure: Submit an application by 30 September of the following year (e.g., by 30 Sep 2026 for VAT incurred in 2025). The application is made in the business’s own country tax portal, which forwards it to Denmark. [taxation-c….europa.eu]
- Information required: The claim form will list each expense, supplier, date, amount, VAT, and a category code (e.g., 1 for fuel, 2 for accommodation, etc.). Invoices above a threshold (likely €1,000 or so, or €250 for fuel) require attaching a copy.
- Minimum claim: If claiming for less than a year (but at least 3 months), minimum VAT amount is DKK 3,000. For a full year or the remainder of a year, minimum DKK 400. [taxation-c….europa.eu]
- Allowable expenses: Typically include VAT on hotel accommodation, meals (if not extravagant), transport hire, fuel, training, trade fairs, professional service VAT etc., provided a Danish business could also deduct such VAT. Items like cars, entertainment remain non-deductible (so a foreign business can’t get Danish VAT back on a client dinner either, since a local couldn’t deduct it).
- Timeline: Denmark is supposed to respond within 4 months (can extend to 8 months if asking for info). If approved, refund is paid to the claimant’s bank account (possibly in DKK or as requested). [taxation-c….europa.eu]
- Denmark processes these fairly efficiently; communication on queries is done electronically via the portal and sometimes email.
- No fiscal rep is needed for EU 8th Dir claims (the home country tax authority identity is enough).
- Example: A German consultant (VAT-registered in DE) attends a conference in Copenhagen and pays 25% Danish VAT on hotel and car rental. They can, by Sep 30 the next year, claim that VAT back from Denmark via the German online portal, and Denmark will refund it within months, since those are deductible business expenses.
16.2 Non-EU 13th Directive Refunds
- Denmark does not require reciprocity (they refund to any non-EU country’s businesses, even if that country doesn’t refund to Danes). This is generous, as some EU states need reciprocity. [taxation-c….europa.eu], [taxation-c….europa.eu]
- Non-EU companies must submit claims directly to Denmark (Skattestyrelsen). There’s a specific form and procedure (often form 31.4 or similar).
- Deadline: The claim must arrive by 30 September of the year following the refund year (same deadline as EU claims in practice). [taxation-c….europa.eu]
- Period & minimum: Same minimum amounts: DKK 3,000 for part-year, DKK 400 if full-year. [taxation-c….europa.eu]
- Submission: Claim forms can be downloaded from skat.dk and must be filled (in English/Danish/German/Swedish) and mailed to the Tax Authority’s special unit in Sakskøbing. [taxation-c….europa.eu]
- Documents: Original invoices must be mailed with the claim. Also required is a certificate of status from the home country (proof the claimant is a business subject to VAT/sales tax there). This is usually a form stamped by home tax authority, valid for up to a year. [taxation-c….europa.eu]
- Processing: Denmark will review and should respond within 6-8 months. If approved, refund is paid, possibly by bank transfer. The claimant may need to provide bank details (including IBAN, SWIFT). [taxation-c….europa.eu]
- Representative: Denmark’s FAQ says a foreign business doesn’t need a fiscal representative for a refund, but if they use an agent to handle paperwork, a power of attorney must be given. [taxation-c….europa.eu]
- Eligible VAT: The same logic – only VAT on business expenses related to taxable activities can be refunded. If the business engages in exempt activities (like a foreign bank’s travel expenses in DK while doing exempt financial business) — that might be disallowed because a Danish business doing exempt work couldn’t get VAT back either. So typically the foreign business needs to affirm that the expenses relate to taxable/out-of-country activities that would allow VAT recovery if they were Danish.
- Ineligible: VAT on goods that are exported (should have been zero VAT if done right; if they erroneously paid VAT, they might need to adjust invoice rather than refund). Also if the foreign firm is registered or should be registered in DK, they can’t use this (they must register instead).
- Example: A US company sends staff to a trade fair in Denmark and they incur VAT on hotel and local taxi. The US company can file a 13th Directive claim by Sep 30 next year with receipts and a certificate from IRS or local chamber verifying they’re in business. Denmark would refund the VAT on hotel (fully, if business travel) and taxis (if considered transport, likely yes) within some months.
16.3 Reciprocity Requirements
- For example, a company from Country X (which doesn’t refund foreign VAT) can still get Danish VAT back.
- This policy makes Denmark quite open; it likely reflects Denmark’s desire not to discourage trade or tourism.
- The only things that matter are the business nature of expenses and not having a taxable presence in DK, not the home country’s policies.
16.4 Need for Fiscal Rep
- For VAT registration needs, as discussed in section 8, non-EU companies do need a fiscal rep in Denmark to register for VAT (except some countries). [vatcalc.com]
- But in the context of pure refund (no registration), no fiscal representative is needed. The business deals directly with the tax authority (or through a chosen agent). [taxation-c….europa.eu]
- Indeed, the EU questionnaire at line 36-42 confirms Denmark does not require appointing a tax representative to apply for refunds, only a power of attorney if an agent files on your behalf. [taxation-c….europa.eu]
- So, a Canadian company can file its refund claim without having a Danish fiscal rep.
- If a non-EU business decides to voluntarily register in Denmark to regularly claim input VAT, then a fiscal rep is needed (with joint liability). But that is a different path; usually one sticks to the refund route unless they also have output to declare.
17. VAT on Digital Services
- B2C digital services: Since 2015, all electronically supplied services (e.g. apps, streaming, downloads, e-books, online gaming services, etc.) supplied to EU consumers are taxed in the consumer’s member state. So Danish consumers buying digital services should be charged Danish VAT. A Danish company providing digital services to an EU consumer outside Denmark must charge that country’s VAT once above threshold, typically via OSS. [vatabout.com]
- For Danish businesses selling digital services to consumers in other EU countries: up to a small EU-wide threshold of €10,000, they can charge Danish VAT; beyond that, they must charge the customer’s country VAT. To simplify, they would register for the OSS (One-Stop Shop) Union scheme, as covered in 5.3, to remit foreign VAT easily. [vatabout.com]
- For non-EU companies selling digital services to Danish consumers: they must register either for the Non-Union OSS scheme or appoint a Danish VAT representative to handle VAT. OSS is the common choice. They charge 25% Danish VAT on those sales. [vatabout.com]
- Denmark’s implementation: They use the definitions from the EU regulation – “Electronically Supplied Services (ESS)” are e-services delivered over the internet with minimal human involvement. They rely on the OSS MOSS systems for compliance. [vatabout.com]
- B2B digital services: follow general B2B rule – e.g. a software license provided to a Danish business from abroad is just reverse-charged by the Danish business (no special rule needed).
- Digital publications: Starting 2020, Denmark (like other EU) could apply reduced or zero rates to e-publications. Denmark’s plan to zero-rate books might extend to e-books by 2026. But currently, e-books and digital newspapers would still be at 25% (unless they implement similarly). [vatcalc.com]
- Telecommunications & broadcasting: treated similarly to e-services for place of supply – B2C taxed in consumer’s country (and subject to OSS).
- Use and enjoyment (from 15.9): Denmark taxes even non-EU to DK consumer digital service using use & enjoyment provisions, ensuring no one outside EU can supply digital to Danes VAT-free. Conversely, presumably if a Dane supplies telecom to a non-EU consumer where normally EU says “tax in EU”, they might not tax if used abroad. [vatcalc.com]
- Administration: The OSS returns for these digital services are quarterly. Denmark’s Tax Agency receives OSS data from other countries for sales into Denmark and will get the revenue accordingly.
- Compliance for Danish digital businesses: If a Danish business sells, say, e-learning courses to consumers in various EU states, it must track those sales by country. If total B2C EU sales > €10k, it must collect each country’s VAT. The simplest is to use OSS (through the Danish tax authority’s OSS portal). They would include their Danish domestic B2C sales still in their normal VAT return, and all foreign B2C in the OSS return. The OSS registration in Denmark (since it’s their home) covers all EU consumer sales outside DK.
- Non-EU digital sellers: If not using OSS (which they should), they’d have to register individually – far less common now due to OSS.
18. Distance Selling Rules
18.1 Thresholds
- If an EU business’s total B2C sales of goods (to all EU countries other than its own) plus B2C digital services exceed €10,000 per year (about DKK 74,000), then all those sales become subject to VAT in the destination country from the first euro (i.e. no country-specific limit). [vatabout.com]
- If below €10k, the business can opt to just charge its home country VAT on those sales (and then destination countries forego the tax), but it can also voluntarily use OSS to charge destination VAT anyway.
- Foreign EU sellers no longer have a unique Danish threshold; it’s just part of the €10k pan-EU threshold. [vatabout.com]
- If a German webshop exceeds €10k in EU sales, then all its sales to Denmark must have 25% Danish VAT (likely via OSS).
- If it doesn’t exceed, it can continue charging German VAT to Danish customers.
- Many small EU sellers with cross-border sales likely exceed €10k quickly, so practically most charge destination VAT now.
- If they stock goods within the EU (like via Amazon fulfillment in EU), then rules of distance selling apply as if from that EU country.
- If shipping from outside, then they either use IOSS (for <€150 shipments) or the buyer does import formalities.
18.2 OSS/IOSS Participation
- OSS (One-Stop Shop) – Union Scheme: EU sellers can register for Union OSS in their home country to report all B2C sales to other EU countries. Instead of registering in each country (like Denmark), they file one OSS return that covers Danish VAT on Danish deliveries, etc. This greatly reduces administrative burdens. [vatabout.com]
- Denmark is fully integrated into OSS. So a Swedish company selling to Denmark will likely just use Sweden’s OSS to remit Danish VAT.
- OSS returns are quarterly, separate from domestic VAT returns. Payment is sent to home tax authority who distributes to each country.
- IOSS (Import One-Stop Shop): For imports to consumers not exceeding €150, non-EU or EU sellers can use IOSS to charge VAT at point of sale and streamline import. Denmark participates, meaning any IOSS-registered seller who sells to Danish customers will include Danish VAT in price and the goods clear customs VAT-free (since it’s prepaid via IOSS to Denmark’s tax). [vatabout.com]
- IOSS is optional but beneficial to expedite delivery (consumer doesn’t face fees on arrival).
- If IOSS not used, the shipment above €150 requires normal import VAT, and either the consumer or courier handles it.
- Ending of VAT exemption: Prior to July 2021, imports under €22 were VAT-free. That exemption was removed. Now everything is subject to VAT, making IOSS important for small parcels.
- Denmark’s national systems accept IOSS identification on parcels to waive collecting VAT at customs for those.
- If selling online to other EU countries’ consumers: They must either monitor the €10k threshold. If they exceed it (combined EU sales), they should register for OSS (Union scheme) and start charging each country’s VAT. Many presumably opted into OSS from the start in 2021. [vatabout.com]
- If below threshold, they can choose to still use OSS, or keep charging Danish 25% for all EU sales. But that might short-change some countries (the rule allows it legally though until threshold hit).
- Many by default join OSS to avoid risk of passing threshold mid-year.
19. Cash Accounting Scheme
- Denmark did not implement an official cash accounting regime up to a high threshold like the UK or some others. It’s not listed as available. [vatcalc.com]
- This means even small businesses on biannual reporting must pay VAT on their sales before the customer may have paid them, potentially.
- One minor exception: For very small part-time businesses under the threshold (DKK 50k), since they don’t have to register until they exceed it, effectively they are outside VAT until they grow.
- In some cases, the law allows output VAT not to be paid if it’s not collected, but generally not – except via normal bad debt relief (which is after the fact).
- There was historically an option for some professions (like doctors, dentists who used to be partially taxed on some things) to maybe use cash basis, but since many are exempt anyway, not relevant.
- So, as a rule, no simplified cash basis scheme is in place in Denmark (the EU Directive allows it up to €2 million turnover, but Denmark hasn’t implemented it).
- All businesses must therefore be careful with cash flow or negotiate payment terms accordingly, since VAT must be remitted by the due date whether or not the customer paid.
20. VAT-Registered Cash Tills (Point-of-Sale Requirements)
- There is no mandate for “fiscal cash registers” or certified POS systems as in some countries (like Italy or France have).
- Retailers must of course keep proper records and issue receipts, but Denmark has not implemented a special secure element in tills under VAT law up to 2026.
- However, with the new Bookkeeping Act, there is a move towards digital record keeping. Companies will be required to use digital bookkeeping systems which may include their sales records. But that is more about record retention than a physical device.
- Danish law does require that if using a cash register, it should produce receipts and maintain data for 5 years. Many use electronic systems anyway.
- There’s also consumer protection rules that some businesses must offer receipts upon request.
- Specific sectors: We are not aware of any sector (like hospitality) needing certified tills, aside from normal accounting.
- Summaries from sources indicate “N/A” for special cash till requirements – meaning no special VAT-registered cash register obligation. [vatcalc.com]
- Just general requirement: if a cash business is using simplified invoices/receipts, they must sequentially number them, etc., but this is standard.
- A future possibility: If Denmark implements electronic real-time reporting or standard audit file, they might indirectly require more from POS. But as of now, none.
21. Statute of Limitations
- In Denmark, the general limitation period for making adjustments to VAT returns is 3 years. This means the tax authorities typically have 3 years from the submission deadline to audit and demand changes, and similarly businesses can correct errors within 3 years. [vatcalc.com]
- Specifically, if an error occurred in a VAT period, a business has up to 3 years to submit a corrective return (after which the ability to reclaim overpaid VAT might close).
- The authorities also have 3 years to issue additional assessments for underpaid VAT, unless fraud or willful misconduct is involved.
- Fraud or evasion cases: If there is evidence of intentional tax evasion or fraud, the limitation is extended (often up to 10 years, or effectively no limit until caught). The vatcalc note says “unless evidence of fraud” – thus in fraud cases they can go beyond 3 years. [vatcalc.com]
- There was an important change: Starting mid-2023, interest on corrections is charged retroactively (as covered in Penalties); that also encourages timely corrections within that 3-year window because beyond it, severe interest or inability to correct possible.
- The 3-year period is counted from the end of the calendar year in which the VAT was due, possibly. But it might be from the filing deadline. Usually, e.g., Q1 2022 return due by June 1, 2022 – the tax authority has until sometime in 2025 or early 2026 to revise it.
- If taxpayers discover errors after 3 years, they can apply for a special relief but it’s not guaranteed.
- It’s simpler than some countries which have 5 years; Denmark’s 3 years is relatively short.
- For voluntary disclosures within 3 years, interest from July 2023 is 0.7% per month from original due date, but at least it can be corrected. After 3 years, one might not legally owe it (unless fraudulent), but if fraud, then penalties and longer reach. [vatdesk.eu], [vatdesk.eu]
22. VAT Return Filing
22.1 Filing Frequency
- Monthly filing: Required for large businesses with annual turnover above DKK 50 million (~€6.7 million). These businesses file 12 VAT returns per year (one for each month). [vatabout.com], [eurotax.fr]
- Quarterly filing: For medium-sized businesses with turnover between DKK 5 million and DKK 50 million (~€0.67m to €6.7m). They file 4 returns a year (Q1, Q2, Q3, Q4). [vatabout.com], [eurotax.fr]
- Semi-annual (half-yearly) filing: For small businesses with turnover under DKK 5 million (~€670k). They file 2 returns per year (covering Jan–June and July–Dec). [vatabout.com], [eurotax.fr]
- Newly registered businesses: Typically default to quarterly filing initially, regardless of expected turnover. After some time (or at the next annual review), their frequency might be adjusted if their actual turnover falls in a different bracket. [vatabout.com]
- The tax authority automatically re-evaluates a company’s turnover each year and may reassign it to a different filing frequency (usually each January) if needed. Businesses cannot usually choose a frequency at will; it’s mandated by turnover. However, a business can opt for a more frequent schedule than required if they prefer (e.g., a small business might opt to file quarterly instead of semi-annually to get more timely refunds, but this might need approval). [fintua.com]
- The thresholds mentioned are current as of 2026; they can be adjusted by law, but these have been stable.
- If a company is part of a VAT group, the group as a whole likely files at a frequency based on the group’s combined turnover.
- If a business repeatedly fails at timely filing for a larger period, tax authorities might move them to a more frequent schedule as a risk measure, but not sure if Denmark does that.
22.2 Method
- The filings are done through the TastSelv Erhverv (electronic self-service for businesses) on skat.dk. This is the official online portal. [vatcalc.com]
- Businesses log in (with a NemID/MitID or employee signature) and complete the VAT return form online. Alternatively, data can be uploaded if integrated via API or software.
- Since 2014, paper filing is not accepted except perhaps in extraordinary cases.
- Payment of VAT also is electronic:
- Usually via bank transfer to the company’s “Tax Account”. Many set up the “NEM konto” (Easy account) or use the LeverandørService direct debit system to ensure timely payments. [eurotax.fr]
- As noted, cash or checks are not accepted for VAT. [eurotax.fr]
- Companies can also use online banking with the correct reference or sometimes card payment through the portal.
- The system is quite straightforward: you report total output VAT and total input VAT, or sometimes only the net amount to pay/credit. But likely they have fields such as “Sales excluding VAT”, “Taxable purchases”, etc for statistical if needed, though many countries simplified to just net.
- Language: The portal is in Danish, but some guidance available in English. Many international firms have their agent or local accountant handle it.
- Non-resident businesses filing Danish VAT (if, say, they had to register outside OSS) also must e-file. They get a Danish login or upload via certain ways.
- There’s also an integration with accounting software for direct submission (through the SKAT API).
- Summarily, the method is digital-only filing and payment. The days of mailing a form and a check are long gone. [vatcalc.com]
22.3 Deadlines for Filing and Payment
- Monthly returns: Due by the 25th of the following month. For example, January’s VAT return must be submitted and paid by February 25. If the 25th falls on a weekend or holiday, the deadline moves to the next working day. [vatcalc.com], [eurotax.fr] [vatcalc.com]
- Quarterly returns: Due by the 1st day of the third month following the quarter. This effectively means two months plus a day after quarter end: [vatcalc.com], [eurotax.fr]
- Q1 (Jan–Mar) due 1 June,
- Q2 (Apr–Jun) due 1 September,
- Q3 (Jul–Sep) due 1 December,
- Q4 (Oct–Dec) due 1 March of next year. If those dates land on a weekend, next business day.
- Semi-annual returns: Also due by the 1st day of the third month after period end: [vatcalc.com], [eurotax.fr]
- H1 (Jan–Jun) due 1 September,
- H2 (Jul–Dec) due 1 March of next year.
- There’s mention of a special slight extension for June: Possibly Denmark gives a small extra relief for the second quarter deadline which falls around summer. The Eurotax snippet says “For June, returns can be filed by 17 August”. This suggests that for monthly filers, the June return (due July 25 normally) might have a one-time extension to August 17 due to summer; or for quarterly Q2 due Sep 1, maybe they allow Aug 17 for payment? It’s unusual. It’s possible this is an outdated reference to COVID measures or a misinterpretation. Typically deadlines are fixed as above. However maybe historically Denmark gave companies a bit more time for the June month (covering summer vacation). Not confirmed widely elsewhere. [eurotax.fr]
- Payment deadlines are the same as filing deadlines. Payment is expected by the due date of the return. If a return shows a refund, that will be processed after filing. [eurotax.fr], [vatcalc.com]
- Companies on OSS/IOSS have separate deadlines:
- OSS returns (quarterly) are due by the end of the month following the quarter (April 30, July 31, Oct 31, Jan 31).
- IOSS returns (monthly) due end of the following month. But those are handled in respective OSS systems, not via regular VAT returns, so outside main discussion except mention if needed.
- If a business has no sales or purchases in a period, they still must file a “zero return” by the deadline. [skat.dk]
22.4 Pre-Filled Return Availability
- Some countries have started pre-filling returns using data from purchase invoices (via SAF-T or e-invoicing) but Denmark hasn’t implemented this yet.
- Given Denmark is moving towards digital bookkeeping and SAF-T, in the future they might cross-check or pre-populate portions (like auto-calculating if they have your sales data).
- As of 2026, businesses must compile their own totals. There is no automatic retrieval of sales/purchase info by the tax authority for return preparation.
- So likely the answer: No, Denmark does not issue pre-completed VAT returns to taxpayers; the onus is on the taxpayer to report.
22.5 Handling of VAT Credits/Refunds
- The taxpayer can request a refund on the VAT return. In Denmark, excess VAT is normally refunded automatically by the tax authority, typically within a few weeks after the filing. [vatcalc.com]
- The refund is usually paid to the business’s NEM-Konto (a designated bank account for government payments).
- There might be a slight delay if the amount is large or if the account has other tax arrears (the system might offset the refund against other tax debts first).
- The vatcalc note: “VAT credits: via VAT return with automatic repayment. This may however trigger a VAT audit..” So routine refunds are paid out, but a significant or unusual refund can flag the tax authority who might verify the claim before releasing funds. [vatcalc.com]
- If Skat decides to audit or validate, they may withhold or delay the refund until information is checked (but they must normally do so within a reasonable time).
- Frequent refunds might cause the business to be moved to monthly filing so that they can get refunds quicker (especially exporters).
- The Tax Account (Skattekonto) system in Denmark consolidates all tax types. If a VAT return shows a refund, it posts as a credit on the Tax Account; if the account is overall positive, it disburses after a set interval (some days). If negative (owing other taxes), it offsets.
- Businesses do not need a separate claim form beyond the return; marking the return negative triggers the process.
22.6 Correction of Errors
- The law requires that adjustments be made in the return for the period to which they relate. So you can’t just put an extra negative or positive amount in the next return; you should correct the original quarter’s figures. [vatdesk.eu]
- In TastSelv system, one can typically reopen a past period (within the 3-year limit) and submit a corrected return for that period.
- Prior to mid-2023, some minor under/over could be adjusted later, but now interest rules encourage doing it properly in the actual period.
- Late interest: As of July 1, 2023, any correction that results in additional VAT due for a past period will incur interest at 0.7% per month from the original due date. This applies whether the error is found by the company (voluntary disclosure) or by audit. That is a new crackdown measure. [pwc.dk], [vatdesk.eu]
- No interest compensation for the state if it was an overpayment corrected late, though.
- The taxpayer can file a corrective declaration via the portal. The portal might require contacting the tax authority to unlock old periods if beyond a certain time.
- Also note, if the error is discovered beyond the 3-year statute (and not fraud), you might not be allowed to correct it (if it’s in favor of taxpayer).
- Minor rounding differences typically don’t require correction. But anything material should be fixed.
- If a business has systematically underdeclared, they should do voluntary disclosure to avoid higher penalties. Usually, if voluntarily disclosed before audit, only interest and a minor fine might apply, vs heavy fines if caught.
- For OSS returns – corrections similarly must be done in a special way (OSS has its own correction rules).
- The VATDesk piece [20†L21-L29] explicitly says in Denmark adjustments cannot be made in the following return but must go in the period they belong. This has now been backed by interest consequences if not. [vatdesk.eu]
22.7 Non-Resident Filing Specifics
- They are assigned a Danish CVR/VAT number and a filing frequency based on their Danish turnover (often they’ll be quarterly by default).
- They must file electronically via TastSelv like anyone. If they have no NemID, the system allows login with a special username.
- They usually must appoint a fiscal representative if non-EU (except exceptions), who will often handle the filings for them. [vatcalc.com]
- The deadlines and procedures are the same – e.g., a non-resident with quarterly filing must file by 1 March, etc.
- One difference: Non-residents typically would never be on semi-annual; they usually start on quarterly even if small activity, as far as practical matters go.
- They also can request refunds or offset credits similarly. If a non-resident consistently has no taxable sales and just incurring Danish VAT, perhaps direct refunds (13th directive) might have been more appropriate than registration.
- If a non-EU company was forced to register and then later leaves (deregisters), they cannot use the Directive refund scheme for any period they were registered; they should handle final adjustments through their last return.
- The Copenhagen Business Authority might be involved in handling some non-resident accounts (the reference [14†L27-L30] mentions they handle non-resident-related matters).
- Otherwise, “Largely same as resident” covers it: yes, they abide by the same return schedule, digital filing, and deadlines, with the caveat of requiring a fiscal rep if applicable. [vatcalc.com]
23. Other Filings
23.1 EU Sales List (ESL)
- If a business makes intra-Community supplies of goods or certain services to other EU businesses, it must file an ESL, listing each customer’s VAT number and the total value supplied to them in that period. [vatabout.com]
- The ESL is usually filed on a monthly basis, which is standard for most companies as it ties with monthly or quarterly schedule: [vatcalc.com]
- If the company files VAT monthly, they do ESL monthly.
- If quarterly and the values are small (under DKK 400k per quarter), Denmark allows quarterly ESL. Otherwise, if making larger EU sales, likely monthly is expected even if on quarterly VAT. [vatcalc.com]
- The deadline for ESL submission is the 25th of the month following the reporting period. So for January ESL, due 25 Feb; for Q1 (if allowed quarterly), due 25 April, etc. [vatcalc.com]
- ESL must be filed electronically, often through TastSelv or via the IDEP.web portal provided by Statistics Denmark (which can do combined Intrastat & ESL). [vatabout.com]
- Services included: Only those B2B services that fall under the “article 44” general rule do not get listed (they’re handled by reverse charge, but not listed). However, certain specifically reportable services (like B2B sales of goods with installation, or maybe intangible services if required by EU in listing? Actually as of 2010, many member states had to include B2B sales of services that are tax-shifted. The EU Sales List in EU now includes Cross-border B2B services that are subject to reverse charge, if those services fall under the scope of EU VAT and are taxable at customer. So yes, Denmark likely requires listing cross-border services under the VAT Package rules delivered B2B to EU. Confirm: [9†L121-L129] suggests ESL contains goods and services to other VAT-registered persons.)
- Non-EU exports are not on ESL, only intra-EU sales.
- If no EU sales in a period, typically no ESL required for that period (or a nil ESL can be filed, some countries require nil ESL, unclear if Denmark does; likely not needed if none).
23.2 Intrastat
- Authority: In Denmark, Intrastat is managed by Statistics Denmark (Danmarks Statistik).
- Thresholds: As of 2026, Denmark’s Intrastat thresholds are:
- Arrivals (imports from EU) above DKK 42 million yearly (it was 41m, raised to 42m in 2026). [vatcalc.com], [vatcalc.com]
- Dispatches (exports to EU) above DKK 11.8 million yearly (raised from 11.3m to 11.8m as of 2026). [vatcalc.com], [vatcalc.com]
- If a business’s EU trade exceeds those in a year, they must start Intrastat reporting.
- There are two “groups” often: Group 1 (large reporters) and Group 2 (smaller above threshold). Group 1 might report more details or earlier deadlines.
- Deadlines: Typically monthly Intrastat reports are due by the 10th working day or a set day (often around the 10th) of the following month. The snippet says for DK: [vatcalc.com]
- Larger reporters (Group 1) have an earlier deadline,
- Smaller (Group 2) a later deadline. Possibly Group 1 by 10th, Group 2 by 15th or so. Actually [13†L22-L24] states new thresholds 2026: Arrivals threshold unchanged at 42m; dispatch threshold changed from 11.3 to 11.8m. But not explicit deadlines. [vatcalc.com]
- From [1†L20-L28], group definitions in Fintua: Group 2 (smaller) is if imports <41m and exports 11.3-16.5m; Group 1 if imports >41m or exports >16.5m. Those groups correspond to earlier and later deadlines indeed.
- Data required: value, weight, commodity code, partner country, etc.
- Businesses not meeting thresholds can voluntarily report but not required.
- If a company fails to submit Intrastat, Stats Denmark may send reminders or estimates and eventually fines (though enforcement historically mild).
- Combined reporting: Denmark’s “IDEP.web” allows submission of both ESL and Intrastat together if needed.
23.3 Annual Returns
- The quarterly/semi-annual returns cover the liability; no additional final return is needed provided all periods are filed.
- At year-end, businesses do have to finalize their partial exemption calculation (pro-rata) and adjust via a specific period’s return (the rule said must adjust in the first return after financial year, which for calendar year means the June return of next yr). But there’s no separate form to file to authorities for that – it’s done within the periodic return. [pwc.dk]
- When deregistering, you file a final return, but that’s not exactly an “annual” either.
- So, no annual VAT statement is required in Denmark. This simplifies compliance, as businesses just ensure all periodic returns are correct.
- They do file annual financial statements to SKAT for income tax, but VAT data is not summarized there except through audit references.
23.4 SAF-T or Other Digital Reporting Requirements
- The 2022 Danish Bookkeeping Act requires that companies keep electronic records and be able to export accounting data in a standard SAF-T format when requested. [vatabout.com]
- The adoption is phased: From January 2024, large companies had to comply; from January 2026, even foreign companies registered in DK with turnover > DKK 300k in 2 years must comply. Essentially: [vatabout.com]
- By 2026, most VAT-registered businesses (local and foreign) need to use a digital bookkeeping system meeting certain criteria (e.g. storing data electronically, producing SAF-T). [vatabout.com]
- SAF-T (Standard Audit File–Tax): Denmark’s Erhvervsstyrelsen (Business Authority) has developed a SAF-T schema for Denmark. Companies’ systems must be able to generate this file (which includes general ledger, customer, supplier, invoice data) if tax authorities ask. [vatcalc.com]
- Currently, Denmark does not require ongoing real-time submission of SAF-T or continuous transaction reports. It’s more a readiness requirement. However, the direction is toward more digital oversight.
- Continuous Transaction Controls (CTC): Denmark is considering e-invoicing mandates in future. The timeline suggests by 2026 to have conditions in place, but as of now B2B e-invoicing remains optional (though systems must support it).
- The Bookkeeping Act aims to combat fraud by ensuring records can’t vanish. The law includes fines for not having a compliant digital system after the deadlines.
- There is no requirement to submit SAF-T periodically; just to have it available.
- No SAF-T submission portal in routine use (only if asked during audit).
- Also, large companies might have to file a VAT reconciliation or partial deduction percentage annually (like new rule to report their pro-rata by June 2024 as Deloitte noted) through e-tax, which is a new digital reporting element for those with mixed use.
- For now, main additional “digital” requirement: ensure your accounting software meets Danish standards for data export and e-invoicing capability.
24. Penalties and Interest
24.1 Late Filing Penalties
- When a return is missing by the deadline, Skattestyrelsen will often send a reminder and then make a preliminary assessment of VAT due (often a punitive high estimate) for that period. This forces the taxpayer either to correct by filing or face paying that estimate. [vatabout.com]
- For each VAT period that is filed late (or not filed), Denmark charges a fee of DKK 800 per reminder/assessment. The vatcalc indicates DKK 800 for a late return initial penalty. [vatcalc.com]
- If the company still delays and the tax authority has to put extra work (like performing an estimate or audit due to non-filing), an additional penalty of DKK 1,000 can apply after review. [vatcalc.com]
- The VATabout source said: “The penalty for [estimated report] is DKK 1,400 for each period the person is late”. Possibly that 1,400 represents the combined administrative fees or a standard cost for them making the estimate. It might be that they charge 800 for missing, and 600 for the effort, totalling 1,400, or the rules changed to 1,300/1,400. In any case, expect around DKK 800-1,400 per return missed as a fine. [vatabout.com]
- Importantly, if returns continue to be missing, the authority can deregister the business (forced deregistration) and pursue collection of their estimated VAT. [vatabout.com]
- Additionally, criminal penalties can come into play if non-filing is willful to evade tax.
- But for simple lateness, it’s usually administrative fines rather than court.
- It’s always best to file even a zero or estimated return than not file at all, to avoid those fees.
- If a company finds they must file late, there’s no extension really, but any penalty perhaps can be appealed with reasonable cause (like director illness).
- There’s no daily interest for late filing itself – interest is on late payment (discussed below), but late filing triggers these fixed fines.
24.2 Late Payment Interest Rates
- Historically, interest on late paid VAT was somewhat unusual (Denmark didn’t charge interest unless fraud). But a new legislation from mid-2023 introduced interest on all late payments and corrections. [pwc.dk]
- The current rate is 0.7% per month of delay (which is ~8.4% annual). This rate applies to the period from due date until payment. It is simple interest not compounded under the new rules after 2025 (they moved to simple interest). [pwc.dk], [vatdesk.eu]
- If a business corrects an old return and owes more VAT, interest from original due date to payment will be charged at 0.7% per month. [pwc.dk]
- If they just paid late (no correction, just paid after deadline), interest accrues similarly from the day after due date.
- The interest is often posted on the Tax Account as a charge.
- Additionally, the tax authority sends a reminder fee of DKK 65 for each formal reminder letter (as noted in vatcalc: “DKK 65 for each reminder”). [vatcalc.com]
- If still unpaid, further fines up to DKK 10,000 can be added once reviewed by authorities (this might be a penalty for significant underdeclaration or repeated offenses, separate from interest). [vatcalc.com]
- In serious cases of non-payment, criminal penalties can escalate (fines larger or imprisonment if fraudulent intent).
- But for normal late payment (a short delay), likely just interest and maybe a small reminder fee.
- Interest example: If you owe DKK 100,000 VAT due March 1 and pay on April 1, one month late, interest ~0.7% of 100k = DKK 700 charged.
- If multiple months, each month another 0.7% of original amount (simple interest means presumably each month 700, so 2 months = 1.4% etc).
- Before 2023, interest was rarely applied except for fraud. Now it’s automatic. So this is a big change.
- The EY snippet [16†L1-L9] indicates new interest on late tax from 2025 (maybe switching to simple from compound or different enforcement).
- According to VATDesk [20†L27-L30], a 3-year old undeclared VAT would accumulate ~28.55% interest (0.7% * 41 months). That clearly shows the per-month accrual method. [vatdesk.eu]
24.3 Other Fines
- Incorrect invoicing: If a company charges VAT incorrectly (like not charging when should, or charging when not allowed), they can face penalties or be liable for that VAT. In 2025, updated guidance to allow refunds of incorrectly charged VAT to the supplier if they correct it properly was issued, but if they don’t correct, they might face paying VAT twice or fines. [vatcalc.com]
- Failure to register: Not registering when required (e.g., surpassing threshold and not signing up) can incur fines. Typically, if caught, they must pay the VAT due and possibly a penalty for operating unregistered. Fines can be significant (maybe a percentage of undeclared VAT).
- Fraudulent evasion: This is criminal. Depending on severity, a fine or even prison. Denmark has jailed individuals for serious VAT carousel frauds, etc.
- Special sectors: If a company misuses the reverse charge or grouping to evade tax, penalties under anti-avoidance can apply.
- Payroll tax: out of scope but if a company should have been paying the special payroll tax due to exempt status (like a financial co. not VAT paying but should pay payroll tax) and doesn’t, separate fines there.
- The text [14†L84-L85] mentions: “further fines of up to DKK 10,000 once reviewed”. This likely refers to an additional fine for continued non-compliance or inaccurate filing after authority review. Possibly per offense or a general cap for certain administrative fines. [vatcalc.com]
- If a business underpays VAT (like through mistake but not voluntarily disclosed, and tax authority finds it in audit), typically they will charge the VAT owed, plus interest (0.7%/month now), plus possibly a penalty up to say 20% of the underpaid tax if it’s due to negligence. If deliberate, penalty can be higher (like 1-2x the tax).
- The exact penalty regime for underdeclaration: Many countries have e.g. 0% (voluntary small error), 10% (careless), 20% (serious negligence), 80-100% (intentional fraud). Denmark’s structure might be similar, though not explicitly seen in sources.
- Keep in line with deadlines to avoid automatic fines (800 DKK etc).
- If late, pay ASAP to cut interest accrual.
- Answer information requests to avoid further fines.
- For major issues, consult with tax advisors to minimize penalties (like through voluntary disclosure which can often waive heavy fines, leaving just interest).
25. Other Notable VAT Features
- Special Payroll Tax for Exempt Sectors: Denmark imposes a unique payroll tax (lønsumsafgift) on businesses in certain VAT-exempt sectors (e.g. financial services, insurance, private hospitals, educational institutions). Because these businesses can’t reclaim input VAT (since their output is exempt), the government instead levies a payroll-based tax to ensure they contribute something. For example, banks pay 15.3% on their wage bill as payroll tax. This is outside the VAT system but notable: it effectively compensates for exempt treatment by taxing their “value-add” (wages) directly. It’s an unusual feature of Danish tax law. [taxsummaries.pwc.com] [taxsummaries.pwc.com], [taxsummaries.pwc.com]
- Greenland & Faroe Islands: As mentioned, these regions are outside EU VAT. Transactions with Greenland/Faroe are treated as exports/imports (zero-rated exports from Denmark, and any imports from Greenland/Faroe subject to Danish import VAT as if from a non-EU country). Businesses dealing with those regions must be aware of that status (these areas also have their own sales taxes).
- Margin Schemes: Denmark applies the EU margin scheme for second-hand goods, art, antiques, and collector’s items. Dealers in such goods pay VAT only on the profit margin, not full selling price (with no input VAT deduction on purchase). Similarly, Denmark uses the Tour Operators’ Margin Scheme (TOMS) for travel agencies: VAT on the margin for EU travel services provided to consumers. These are standard EU schemes implemented in Danish law – not unique, but notable if you operate in those sectors.
- VAT on Real Property: While sale of existing buildings and rent of dwellings are exempt, Denmark allows voluntary VAT registration for commercial property leases (option to tax rents) in some cases. Also, sale of a new building or building land is taxable at 25%. Developers can thus recover VAT on construction if the sale will be taxed. This is an important feature for real estate businesses to consider.
- Car leasing rules: Denmark has special rules for leasing of vehicles. Often only a portion of VAT on leasing a car is deductible (if car used for both business/private, 0% on purchase but maybe some allowed on lease, sometimes 50%). Denmark allows some VAT deduction on car leasing (perhaps as EU law minimum 50% for passenger car lease if also private use).
- Digital services taxation aside from VAT: Denmark introduced a digital media levy recently (though not VAT, worth noting): e.g., a 2% streaming levy on revenues of video streaming services (from 2024, rising to 5%) to fund local content. This is separate from VAT but indicates Denmark’s approach to digital economy beyond VAT. [vatcalc.com]
- Environmental taxes: Danish companies face many excise and environmental taxes on products (like a plastics tax, sugar tax, etc.). These aren’t VAT, but often appear on invoices and sometimes businesses claim relief for them. It’s noteworthy that these exist parallel to VAT. [taxsummaries.pwc.com], [taxsummaries.pwc.com]
- No VAT on transfers of going concerns: Like other EU countries, the sale of a business (transfer of going concern) can be outside scope (no VAT) to avoid taxing business takeovers. Danish law provides such relief if conditions met.
- Tax point adjustments for long projects: For long-term construction projects, if progress billings aren’t issued, an annual tax point might be enforced as described in continuous supply.
- Public transportation: Interestingly, international passenger transport is exempt, but Denmark zero-rates domestic passenger flights (to maintain equal footing with international, as per list under zero-rate). Other domestic travel like trains/buses carries 25% VAT (some countries exempt public transport, Denmark does not except flights). [vatcalc.com]
- Charitable organizations: Some supplies by charities can be zero-rated (like second-hand goods sold for charitable purposes, perhaps) or exempt. Denmark likely uses certain EU allowances to zero-rate fundraising sales by charities, etc. mentions charities under zero-rated possibly implying some charitable activities allowed 0% (maybe sales of donated goods). [vatcalc.com]
- VAT fraud measures: Aside from domestic reverse charge expansions, Denmark is active in EU-wide anti-fraud (Eurofisc). They might occasionally freeze refunds if fraud suspected.
- Split Payment / Joint Liability: Denmark does not have a split payment mechanism. But they do hold marketplaces jointly liable for VAT of sellers in some cases (per EU e-commerce rules).
- Penalties for evasion: Large-scale VAT fraud can lead to criminal fines or imprisonment. For instance, carousel fraud might be prosecuted under criminal code. Denmark has had cases of that nature.
- Cross-border cooperation: Denmark exchanges info on car registration tax to ensure if a Dane buys a car in Germany, etc. Not VAT per se, but a related intricacy (imported vehicles require paying heavy Danish registration tax).
- Brexit Note: After Brexit, UK is treated as non-EU for VAT; Denmark did waive fiscal rep for UK businesses (since UK is in list of not requiring rep).
- National VAT campaigns: The government occasionally runs audits focusing on sectors, e.g., restaurants (tips, cash handling) or e-commerce. They also invite small entrepreneurs to courses to educate on VAT, acknowledging complexity.
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