DAC8 Reporting in Denmark: Practical Guide

Denmark has been proactive in addressing the taxation of crypto-assets and has one of the most digitally advanced tax administrations in Europe. The Skattestyrelsen (Danish Tax Agency) is expected to manage DAC8 reporting obligations efficiently, building on its established infrastructure for automatic information exchange. This guide covers the practical aspects of DAC8 compliance for entities operating in Denmark.

National Authority

The Skattestyrelsen (Danish Tax Agency) is the competent authority for tax administration in Denmark, including international exchange of information under CRS, FATCA, and other frameworks. Skattestyrelsen is expected to be responsible for receiving and processing DAC8 reports. The Ministry of Taxation (Skatteministeriet) oversees tax policy and the legislative transposition of EU directives.

Submission Requirements

Denmark's highly digitised tax administration is well-positioned to handle DAC8 reporting through electronic channels.

• Format: Reports should follow the OECD CARF XML schema as specified by DAC8. Skattestyrelsen may publish additional technical requirements and validation rules.
• Language: Tax administration in Denmark is conducted in Danish. However, Denmark's tax authority has experience with international reporting formats. Data fields should follow international standards. Specific language requirements for DAC8 should be confirmed with Skattestyrelsen.
• Submission channel: Denmark may integrate DAC8 reporting into its existing electronic tax systems, such as TastSelv Erhverv (the business self-service portal). The exact submission channel is to be confirmed by Skattestyrelsen.
• CVR number: Reporting entities operating in Denmark typically need a CVR number (Central Business Register number) for tax filings.

Transposition Status

Denmark must transpose the DAC8 directive into national law by December 31, 2025. The transposition is typically achieved through a bill (lovforslag) presented to the Folketing (Danish Parliament). Denmark has generally maintained a strong track record for timely transposition of EU directives. The implementing legislation may amend existing laws on international tax reporting or introduce new provisions.

Local Variations

Denmark may introduce specific national requirements:

• Existing crypto tax rules: Denmark taxes crypto-asset gains and has issued extensive guidance through Skattestyrelsen and the Tax Council (Skatteraadet). DAC8 data may be used to verify compliance with these rules.
• Third-party reporting tradition: Denmark has a strong tradition of third-party reporting, where financial institutions report directly to the tax authority. DAC8 fits naturally into this framework.
• Pre-populated tax returns: Denmark uses pre-populated tax returns extensively. DAC8 data could potentially feed into this system for crypto-asset transactions.
• Finanstilsynet coordination: The Danish Financial Supervisory Authority (Finanstilsynet) oversees financial service providers. DAC8 reporting may be coordinated with MiCA regulatory requirements.

Key Dates

• Transposition deadline: December 31, 2025 (directive must be incorporated into Danish law)
• Data collection begins: January 1, 2026 (reporting entities should start collecting relevant data)
• First reporting period: Calendar year 2026
• First reports due: 2027 (exact date to be confirmed by Skattestyrelsen)

Practical Tips

• Monitor Skattestyrelsen guidance: The Danish Tax Agency regularly publishes guidance on its website (skat.dk). Watch for DAC8-specific publications and technical documentation.
• Prepare for integration with existing reporting: If you already provide third-party reports to Skattestyrelsen, consider how DAC8 reporting can be aligned with those processes.
• Ensure CPR number collection: Denmark uses CPR numbers (Det Centrale Personregister) for individual identification. Ensure your systems can collect and validate these for Danish reportable persons.
• Engage with Skattestyrelsen early: The Danish Tax Agency is generally approachable and may offer opportunities for dialogue with reporting entities during the implementation phase.
• Plan for high compliance standards: Denmark's tax system emphasises compliance and transparency. Ensure your DAC8 processes meet the expected high standards.
• Document due diligence thoroughly: Maintain comprehensive records of all identification and verification procedures performed on reportable users.

Important Notice

This guide provides general information about DAC8 reporting in Denmark. Requirements may change as the directive is transposed into national law. The information presented here should not be considered definitive legal or tax advice. Always consult Skattestyrelsen and the Ministry of Taxation for the latest official requirements. For specific compliance questions, seek advice from qualified Danish tax professionals.