Americans in Denmark

U.S. taxes for Americans in Denmark: what to file, and how to catch up.

Americans in Denmark still file a U.S. return every year, but Danish tax rates usually mean little or no U.S. tax on wages once credits apply. The traps are Danish pension schemes and investment accounts, and Danish funds, which the IRS sees very differently. Most people who fell behind can catch up under the Streamlined procedures, with no penalty if they qualify.

Danish tax yearJanuary – December
Danish return dueMay 1, or July 1
Usual U.S. toolForeign tax credit
FATCA dataShared by Danish authorities
Tax treatyYes

Sound familiar?

How does the IRS treat Danish pensions and savings?

Every one of these goes on your FBAR. What differs is how the IRS taxes them.

AccountU.S. treatment
Folkepension (state pension)Under the treaty, only Denmark can tax it, even for U.S. citizens.Usually fine
Labor market pension (arbejdsmarkedspension)Could be taxable for the U.S. as it builds up, depending on the scheme; the rules aren’t settled.Check first
AktiesparekontoTaxed lightly in Denmark only. For the U.S., dividends and gains are taxable, and funds inside are usually PFICs.Watch out
Danish fundsUsually PFICs (Form 8621), with complex reporting and tax rules.Watch out
Bank accountsInterest is taxable for the U.S., and the accounts count toward your FBAR total.Taxable
Your home and mortgageThe U.S. excludes up to $250,000 of gain on a main home ($500,000 for couples). Paying off a krone mortgage when the krone has fallen can create a taxable currency gain.Plan ahead

Which Danish investments are PFICs?

Danish investment funds (investeringsforeninger), the funds on Nordnet and Saxo, and European ETFs. For U.S. tax they’re passive foreign investment companies, or PFICs, and that doesn’t change inside an aktiesparekonto or a pension.

  • Each fund needs its own Form 8621 in most years, and gains can be taxed at the top U.S. rate plus an interest charge, unless an election was made in time.
  • Denmark taxes some funds yearly on their gains, which can line up better with a U.S. mark-to-market election than with the default PFIC rules. We look at which applies.
  • Not PFICs: shares of individual companies on the Copenhagen exchange, Danish government and mortgage bonds, and bank deposits.

What does the U.S.–Denmark tax treaty actually say?

The treaty was signed in 1999 and updated by a protocol in 2006. For Americans living in Denmark, these parts matter most:

  • The saving clause. The U.S. can tax its citizens as if the treaty didn’t exist, except for the provisions the treaty lists.
  • Social security. The folkepension is taxed only by Denmark, even for U.S. citizens, and U.S. Social Security only by the U.S.
  • Relief from double tax. The U.S. gives a credit for Danish income tax on the same income.
  • Labor market pensions don’t get a clear treaty deferral for U.S. citizens living in Denmark, which is why they need checking.

Social security contributions are covered by a separate U.S.–Denmark agreement, which generally means you pay into one system, not both. Read the U.S.–Denmark tax treaty on IRS.gov.

When are Danish and U.S. taxes due?

Both tax years run January to December, so each Danish year lines up with one U.S. return. Your årsopgørelse from Skattestyrelsen gives most of what the U.S. return needs.

DenmarkUnited States
Tax yearJanuary to DecemberJanuary to December
Annual returnA pre-filled årsopgørelse in March; corrections by May 1, or July 1 if you have foreign or self-employment incomeApril 15, moved to June 15 automatically when you live abroad, or October 15 with an extension
Paying the taxWithheld from your salary through your tax card, with any balance collected the following yearApril 15, even if you file later
Foreign accountsForeign income goes on the Danish returnThe FBAR, due October 15, filed online

Foreign tax credit or exclusion: which wins in Denmark?

Usually the foreign tax credit. Danish tax on a salary, municipal and state, is among the highest anywhere and normally more than the U.S. tax on it. The unused credit carries forward for up to 10 years.

  • The exclusion, up to $130,000 for 2025, is rarely better in Denmark, and it gives up the refundable child tax credit.
  • Families with children can get the refundable part of the U.S. child tax credit, up to $1,700 per child for 2025, by using the credit.
  • Investment accounts are the gap. Spare credit from your salary can’t cover dividends and fund gains, so a lightly taxed aktiesparekonto can leave a U.S. bill.

We run your returns both ways before choosing. How we compare the exclusion and the credit.

A worked example: a researcher in Copenhagen

Lisa moved to Copenhagen in 2017 for a research job and stayed for her Danish partner. She earns DKK 600,000, her employer pays into a labor market pension, and she holds two ETFs in an aktiesparekonto. She hasn’t filed a U.S. return since moving.

ItemHow it’s handled
SalaryDanish tax is higher than the U.S. tax on it, so with the foreign tax credit her U.S. tax on it is $0.
Labor market pensionOn the FBAR. Contributions and growth could be taxable for the U.S., depending on the scheme, so we check it.
Aktiesparekonto ETFsPFICs: a Form 8621 for each, in each year filed.
Filing statusMarried filing separately, so her partner’s income stays off the U.S. return.
Catching upThree years of returns and six FBARs under the Streamlined procedures, with no penalty if she qualifies.

Catching up from Denmark

Most Americans in Denmark who fell behind without meaning to can catch up under the Streamlined Foreign Offshore Procedures: three years of returns, six years of FBARs and, if you qualify, no penalties. If only FBARs are missing, or you’ve moved back to the U.S., another route may fit better. See every IRS catch-up option for expats, compared.

Common questions

Do I pay U.S. Social Security tax in Denmark?

Generally not if you pay into the Danish system. The U.S.-Denmark totalization agreement prevents paying into both systems for the same work in most cases.

Will the U.S. tax my U.S. Social Security in Denmark?

The U.S. taxes it as usual. Under the treaty, Denmark can’t.

How do you handle krone amounts?

We convert using the correct IRS exchange rates for each year and account. It’s routine for us.

Is my folkepension taxed by the U.S.?

No. Under the treaty, only Denmark can tax it, even for U.S. citizens.

Should I keep my aktiesparekonto?

It depends on what’s inside. Funds and ETFs mean Form 8621 every year; individual shares are far simpler. We’ll show you the U.S. cost of keeping it.

My partner is Danish. How do we file?

Usually as married filing separately, so your spouse’s income stays off the U.S. return. If you’re not married, only you file. Married to a non-American.

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