Do Americans living in Denmark still file US taxes?

Generally yes. US citizens and green-card holders file a US federal return on worldwide income wherever they live, and Danish tax residence does not end that obligation. What Danish tax usually does is remove most or all of the US tax through the Foreign Tax Credit on Form 1116 — Denmark's effective rate on employment income typically exceeds the US rate on the same income. The return, and any reporting forms, are still required.

Do Danish bank accounts go on the FBAR?

Generally yes. A Danish bank or brokerage account is a non-US financial account, and its maximum value during the year counts toward the $10,000 aggregate test for FinCEN Form 114. The threshold is the combined peak across every account you own or can sign for, not a per-account figure and not the 31 December balance.

Are Danish ETFs PFICs for US taxpayers?

A Danish investeringsforening, and the European UCITS ETFs sold on Danish platforms, are non-US pooled investment vehicles — and such vehicles commonly meet the §1297 income test (75% or more of gross income is passive) or asset test (50% or more of assets produce, or are held to produce, passive income) that defines a PFIC. It is an annual test applied to the fund rather than a status conferred by domicile, so each holding should be confirmed. For conventional index funds the answer is rarely a surprise.

Does an Aktiesparekonto create US reporting?

The account itself is generally a foreign financial account, so it counts toward the FBAR aggregate and can count toward Form 8938. Whether it also creates Form 8621 reporting depends on what is inside it: individual shares are not PFICs, while Danish or European funds commonly are. The Aktiesparekonto is a Danish tax wrapper with no US counterpart — the US looks through it to the holdings.

Does Saxo Bank create PFIC reporting?

The broker is not what creates it; the holdings are. Saxo's European shelf is UCITS funds, because EU PRIIPs rules keep US-domiciled ETFs off European retail platforms, and non-US pooled funds are generally PFICs — each one generally needing its own Form 8621. Individual shares and directly held bonds at Saxo are not PFICs. The account itself counts toward FBAR and Form 8938.

How are Danish pensions treated in the US?

It depends on the arrangement, and the classification question comes before the treaty. A ratepension, a livrente, an aldersopsparing, ATP and an employer arbejdsmarkedspension are analysed separately for US purposes. Article 18 of the 1999 convention covers pensions, social security and annuities, but the saving clause in Article 1 preserves US taxation of citizens subject to the exceptions listed there — so relief usually arrives as a credit rather than an exemption. Danish tax deferral does not automatically carry across.

Can Danish taxes reduce US tax through the Foreign Tax Credit?

Danish income tax paid on the same income is generally creditable on Form 1116, computed separately by income category and limited to the US tax on that category. Because Danish rates on employment income are high, the credit commonly reduces US tax on that income to zero. Levies computed on a different base — PAL-skat on pension returns, or the annual value-based tax on an Aktiesparekonto — raise creditability and timing questions that are fact-dependent.

Do I need Form 8938 in Denmark?

Possibly, and it is a separate test from the FBAR. For a single filer living abroad, Form 8938 starts at $200,000 in specified foreign financial assets at year end or $300,000 at any point during the year; for married filing jointly the figures are $400,000 and $600,000. Form 8938 also covers a broader class of assets than the FBAR, so the two do not move together.

What if I have never filed US taxes while living in Denmark?

It is usually fixable, and it is the ordinary case the Streamlined Foreign Offshore Procedures exist for. Because Danish tax is high, the tax owed across the catch-up years is often little or nothing on employment income. The work is usually in the information returns — the FBARs, and a Form 8621 for each PFIC for each year, which is what a Danish fund portfolio produces. Start by checking eligibility rather than by guessing at exposure.

Denmark · US corridor

US expat taxes in Denmark —
the Danish accounts the IRS sees differently.

A US citizen living in Denmark generally remains inside the US federal filing system on worldwide income. Danish tax compliance does not end that — what it usually does is remove most of the US tax through the Foreign Tax Credit. The difficulty is elsewhere: an Aktiesparekonto, a Saxo or Nordnet portfolio and a Danish pension are ordinary here, and each is a separate US question with its own forms.

Check my Denmark filing The Denmark treaty desk

Free to start with an on-screen summary — you pay only to generate the package.

Check the common Denmark products

Which of these do you hold?

Pick every one that applies. Each gets its own read — what the US sees inside the wrapper, and which form it points at.

Free, no account, nothing you answer leaves this page. Open the full portfolio scanner

Local accounts and wrappers

Aktiesparekonto holding funds or ETFsAktiesparekonto holding only individual sharesDanish pension holding investment fundsNone of these

A screen from the product type. Whether a specific fund is a PFIC turns on its own annual facts; whether a wrapper is a trust or a pension for US purposes turns on its documents.

What actually applies

The layers a Danish return runs through.

Not everyone needs every form. These are the layers that come up most for Americans in Denmark, and what makes each one bite here rather than somewhere else.

US filing layers that commonly apply to a US person living in Denmark
Form	What it is	What makes it bite in Denmark
Form 1040	The US federal return, on worldwide income.	Filed regardless of Danish residence. Danish salary, A-indkomst and B-indkomst all convert to USD at the IRS yearly-average rate.
Form 1116	Foreign Tax Credit for foreign income tax paid.	Danish income tax is high enough that the credit commonly zeroes US tax on employment income. Computed per income category, which is where a Danish case gets uneven.
FinCEN 114 (FBAR)	Report of non-US financial accounts once the combined peak exceeds $10,000.	Denmark is account-dense: NemKonto, lønkonto, budgetkonto, a Saxo or Nordnet depot, an Aktiesparekonto. They aggregate.
Form 8938	FATCA reporting of specified foreign financial assets, filed with the return.	Higher thresholds than the FBAR — from $200,000 year-end for a single filer abroad — but a broader class of assets, so some Danish holdings appear here and not there.
Form 8621	One per PFIC per year, subject to the form's own triggers.	The Danish fund shelf is Danish and European domiciled. This is where a Danish return stops being routine.
Form 8833	Disclosure of a treaty-based return position that overrides the default treatment.	Not needed for the ordinary Form 1116 credit. Relevant mainly where a specific pension position is taken under Article 18.
Streamlined (Form 14653)	The catch-up route for non-willful taxpayers living abroad.	The common path for Americans who discover the obligation years in. Certified by you, not by software.

A form appearing here does not mean it applies to you. Which of these your return actually needs depends on your accounts, your holdings and your income — which is what the diagnostic works out.

Accounts and investments

Two questions, and they are not the same question.

One is about the accounts you hold. The other is about what is inside them. Danish life produces both.

Danish accounts: reporting, not tax

A NemKonto, a lønkonto, a budgetkonto, a Saxo or Nordnet depot and an Aktiesparekonto are each a non-US financial account. The FBAR test adds them together and looks at the highest point in the year, so several modest Danish accounts can cross $10,000 between them while none does alone.

This layer is informational — it produces no tax by itself. It produces penalties when missed, which is why it catches people who correctly concluded they owed nothing.

FBAR from Denmark, in detail →

Danish investments: where Form 8621 comes from

EU PRIIPs rules keep most US-domiciled ETFs off Danish retail platforms, so a Dane building a diversified portfolio buys Danish investeringsforeninger and Irish or Luxembourg UCITS funds. Those are non-US pooled investment vehicles, and such vehicles commonly meet the §1297 tests that define a PFIC.

A confirmed PFIC generally means generally one Form 8621 per PFIC, per year, with the §1291 default spreading gain back across the holding period with interest unless an election applies. Individual Danish shares — Novo Nordisk, Ørsted, Vestas — are not PFICs.

Check my holdings for PFICs →

If your portfolio is at Saxo

Using Saxo Bank?

Saxo is Danish, and its European shelf is UCITS funds — European ETFs and funds held through Saxo may create US PFIC reporting, one Form 8621 per fund per year under the §1291 default. Individual shares and directly held bonds are not PFICs, and the account itself counts toward FBAR and Form 8938 either way.

Saxo generally does not serve US residents, and its treatment of US citizens resident in Europe varies by entity and has tightened over time. Confirm current terms with Saxo for your own country.

Saxo Bank & PFICs, in full Check my Saxo holdings

Aktiesparekonto

Denmark's simplest investment account is a US look-through.

Introduced in 2019: one account, a contribution ceiling, and a flat annual tax on the change in value instead of tax on sale. Genuinely simple in Denmark — and, for a US citizen, three separate questions wearing one Danish name.

The wrapper has no US counterpart

No US rule defers, exempts or shelters income because it sits in an Aktiesparekonto. The United States looks straight through to the holdings and applies its ordinary rules to each one.

What is inside decides it

Individual shares inside an ASK are not PFICs. Danish investeringsforeninger and European UCITS funds inside one commonly are — the analysis is per holding, on that holding's own facts.

There is no honest blanket answer to “is an Aktiesparekonto a PFIC?”. An account cannot be one.

Lagerbeskatning versus realisation

Denmark taxes the ASK annually on value change whether or not you sell. The US generally taxes on realisation. Danish tax can therefore land in a year with no US income to credit it against, and Form 1116 credits are computed year by year.

Check my investments

The full Aktiesparekonto guide walks the holding types and the Foreign Tax Credit timing problem.

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Check your Danish holdings for PFICs.

Pick your provider — Saxo, Nordnet, a Danish bank, IBKR — and the wrapper you hold it in, or paste the ISINs from your depot statement.

1 · Where do you live?

Where you live changes the products you are likely to hold and the guidance you get next. It does not change how the PFIC rules classify a holding — those turn on the fund, not your address.

2 · Where do you hold it?

3 · What do you hold?

Or paste your ISINs — one per line

Result

Tell us what you hold

Pick the closest match on the left, or paste your ISINs below and we'll flag each one.

More for US taxpayers in Denmark: The Denmark desk.

Educational estimate, not tax advice. Domicile is the fund's legal home, not the broker or exchange you used. Broker and provider policies change — confirm current terms with your provider before acting.

Danish pensions

Classification first, treaty second, reporting regardless.

An American working in Denmark usually ends up in several pension layers at once — folkepension and ATP from the state, an arbejdsmarkedspension through the employer, often a private ratepension, livrente or aldersopsparing on top. For US tax, none of that is one thing.

What the US analysis actually asks

What the arrangement is for US purposes comes before any treaty article: an employer plan, a personal contract with a pension company, a bank-held account, or a state benefit. Danish product names do not settle it, and Danish tax deferral does not automatically carry across.

From there: are contributions currently taxable, is growth currently taxable, what does Article 18 allocate, and what has to be reported regardless.

Danish pensions and US tax, in detail →

PAL-skat, and the 2025 arrangement

Denmark levies PAL-skat at 15.3% on the annual return inside pension arrangements. Whether that is a creditable foreign income tax for you, in which category and in which year, is genuinely fact-dependent — it is computed on a different base and often settled by the institution.

The March 2025 US–Denmark competent authority arrangement clarified which pension entities qualify as a “pension fund” for the Article 10(3)(c) dividend exemption. That is an institutional-investor matter; it does not change how an individual reports a personal Danish pension on a Form 1040.

The Denmark treaty desk →

Behind on filings?

The penalty-free route back, from Denmark.

The typical Danish case is not evasion. It is someone who moved for a job or a partner, paid a great deal of Danish tax for years, and found out from a bank letter. That is the profile the Streamlined Foreign Offshore Procedures were built for.

A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs, with the offshore penalty at 0%. Two gates: your failure to file must have been non-willful, and you must meet the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed.

Because Danish rates are high, the tax across those years is often little or nothing on employment income. The work is in the information returns, and in a Danish case that usually means one Form 8621 per PFIC per year across the whole window.

Non-willfulness is a legal judgement you certify yourself on Form 14653, under penalty of perjury. Atamatax prepares the return side; you write the certification in your own words, assemble the mailing from the package's instructions, and file.

Check my catch-up path The Denmark catch-up guide How Atamatax works

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Rather have a human run the whole catch-up with you?

The Streamlined tiers are quoted in writing once the scope is confirmed, and you accept the quote before any payment. A call is free, optional and available at any point. Where the scope needs a conversation — an open willfulness question, an IRS examination, or facts the intake leaves open — it is offered before any price; otherwise the written quote comes straight from the intake. The exact years, the return/FBAR/Form 14653 deliverables, the price and who does what are all on the quote before you accept it. Booking does not purchase or guarantee a completed Streamlined package.

Book a free 15-min eligibility call What’s included

The call is free and is only a fit and scope check. Non-willfulness is your certification and may require advice from a qualified professional.

The treaty, in short

What the 1999 convention does — and what it leaves alone.

US–Denmark Convention 1999

The convention allocates taxing rights between the two states and provides relief from double taxation under Article 23 — normally as a credit rather than an exemption. The saving clause in Article 1 preserves the United States' right to tax its own citizens as if the treaty had not entered into force, subject to the exceptions listed there.

Article 10 — dividends; Denmark withholds 27% at source, with a lower treaty rate for qualifying residents and the excess recoverable from Skattestyrelsen rather than creditable.
Article 11 — interest. Article 13 — capital gains.
Article 18 — pensions, social security, annuities and alimony; classification of the Danish arrangement comes first.
Article 23 — relief from double taxation, which is what Form 1116 operationalises.
Nothing in the convention displaces the PFIC rules, which are US domestic law.

The Denmark treaty desk, article by article →

The single most common misreading is that a treaty removes the obligation to file. It does not. It decides who may tax what, and provides a mechanism — for a US citizen, almost always a credit — so the same income is not taxed twice at full rates.

The desk sets out the articles one by one, including the March 2025 competent authority arrangement on pension plans and what it does not cover.

The Denmark desk

Every Denmark–US guide on the site.

FBAR for Americans living in Denmark

Which Danish accounts count toward the $10,000 FinCEN 114 threshold, how the aggregate peak is measured in kroner, and what Skattestyrelsen has nothing to do with.

Aktiesparekonto and US tax: what the IRS sees

Denmark taxes an Aktiesparekonto at a flat rate on annual gains inside a sealed wrapper. The United States does not recognise the wrapper at all — it looks straight through to what you hold.

Danish pensions and US tax: ratepension, livrente, aldersopsparing and ATP

Denmark's pension system is layered, and each layer raises a different U.S. question — classification first, then the treaty, then reporting.

Streamlined filing from Denmark: catching up on US taxes

Americans in Denmark who have never filed are usually non-willful, usually owe little after the Foreign Tax Credit, and usually have a penalty-free route back.

Saxo Bank & PFICs for US expats

Saxo's European platform sells UCITS funds — PFICs for a US taxpayer — and the account itself triggers FBAR and Form 8938 checks.

Denmark · US treaty desk

The 1999 convention article by article, with the 2025 pension-plan arrangement.

FBAR & Form 8938 threshold checker

Test your Danish account balances against both thresholds.

All country desks

US filing abroad, adapted to where you live.

Other country desks

The layers a US return runs through don't change by country — what changes is which local accounts, funds and pensions actually trigger them. Here's how Denmark compares.

Italy

Italian funds · pensions · Quadro RW

Germany

UCITS · German pensions · FTC

United Kingdom

ISA · SIPP · UK funds

France

PEA · assurance-vie · PFIC

Canada

RRSP · TFSA · RESP

US taxes in Denmark — the questions we get

Do Americans living in Denmark still file US taxes?#: Generally yes. US citizens and green-card holders file a US federal return on worldwide income wherever they live, and Danish tax residence does not end that obligation. What Danish tax usually does is remove most or all of the US tax through the Foreign Tax Credit on Form 1116 — Denmark's effective rate on employment income typically exceeds the US rate on the same income. The return, and any reporting forms, are still required.
Do Danish bank accounts go on the FBAR?#: Generally yes. A Danish bank or brokerage account is a non-US financial account, and its maximum value during the year counts toward the $10,000 aggregate test for FinCEN Form 114. The threshold is the combined peak across every account you own or can sign for, not a per-account figure and not the 31 December balance.
Are Danish ETFs PFICs for US taxpayers?#: A Danish investeringsforening, and the European UCITS ETFs sold on Danish platforms, are non-US pooled investment vehicles — and such vehicles commonly meet the §1297 income test (75% or more of gross income is passive) or asset test (50% or more of assets produce, or are held to produce, passive income) that defines a PFIC. It is an annual test applied to the fund rather than a status conferred by domicile, so each holding should be confirmed. For conventional index funds the answer is rarely a surprise.
Does an Aktiesparekonto create US reporting?#: The account itself is generally a foreign financial account, so it counts toward the FBAR aggregate and can count toward Form 8938. Whether it also creates Form 8621 reporting depends on what is inside it: individual shares are not PFICs, while Danish or European funds commonly are. The Aktiesparekonto is a Danish tax wrapper with no US counterpart — the US looks through it to the holdings.
Does Saxo Bank create PFIC reporting?#: The broker is not what creates it; the holdings are. Saxo's European shelf is UCITS funds, because EU PRIIPs rules keep US-domiciled ETFs off European retail platforms, and non-US pooled funds are generally PFICs — each one generally needing its own Form 8621. Individual shares and directly held bonds at Saxo are not PFICs. The account itself counts toward FBAR and Form 8938.
How are Danish pensions treated in the US?#: It depends on the arrangement, and the classification question comes before the treaty. A ratepension, a livrente, an aldersopsparing, ATP and an employer arbejdsmarkedspension are analysed separately for US purposes. Article 18 of the 1999 convention covers pensions, social security and annuities, but the saving clause in Article 1 preserves US taxation of citizens subject to the exceptions listed there — so relief usually arrives as a credit rather than an exemption. Danish tax deferral does not automatically carry across.
Can Americans in Denmark use Streamlined Filing Compliance Procedures?#: Residence in Denmark neither qualifies nor disqualifies you. The Streamlined Foreign Offshore Procedures require that your failure to file was non-willful and that you meet the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed. A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs with a 0% offshore penalty. Non-willfulness is a legal judgement you certify yourself on Form 14653.
Can Danish taxes reduce US tax through the Foreign Tax Credit?#: Danish income tax paid on the same income is generally creditable on Form 1116, computed separately by income category and limited to the US tax on that category. Because Danish rates on employment income are high, the credit commonly reduces US tax on that income to zero. Levies computed on a different base — PAL-skat on pension returns, or the annual value-based tax on an Aktiesparekonto — raise creditability and timing questions that are fact-dependent.
Do I need Form 8938 in Denmark?#: Possibly, and it is a separate test from the FBAR. For a single filer living abroad, Form 8938 starts at $200,000 in specified foreign financial assets at year end or $300,000 at any point during the year; for married filing jointly the figures are $400,000 and $600,000. Form 8938 also covers a broader class of assets than the FBAR, so the two do not move together.
What if I have never filed US taxes while living in Denmark?#: It is usually fixable, and it is the ordinary case the Streamlined Foreign Offshore Procedures exist for. Because Danish tax is high, the tax owed across the catch-up years is often little or nothing on employment income. The work is usually in the information returns — the FBARs, and a Form 8621 for each PFIC for each year, which is what a Danish fund portfolio produces. Start by checking eligibility rather than by guessing at exposure.

Authorities cited

US–Denmark Income Tax Treaty — Convention between the United States and Denmark (signed 1999) and the 2006 Protocol
US–Denmark competent authority arrangement (pension plans, 2025) — Competent Authority Arrangement on pension plans qualifying for treaty benefits under Article 10(3)(c), signed 25 March 2025
U.S.–Denmark Totalization Agreement — U.S.–Denmark Social Security (Totalization) Agreement
IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
IRC §1296 — IRC §1296 — Mark-to-market election for marketable PFIC stock
IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
31 U.S.C. §5314 — 31 U.S.C. §5314 — Statutory basis for the FBAR (foreign financial account reporting)
31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)
31 U.S.C. §5321 — 31 U.S.C. §5321 — Civil penalties for FBAR violations (§5321(a)(5))
31 CFR §1010.821 — 31 CFR §1010.821 — Penalty adjustment table (annual inflation adjustments to BSA civil penalties)
Bittner v. United States (2023) — Bittner v. United States, 598 U.S. 85 (2023) — the non-willful FBAR penalty applies per report, not per account
IRC §6038D — IRC §6038D — Information reporting of specified foreign financial assets (Form 8938)
IRS Form 8938 — About Form 8938 — Statement of Specified Foreign Financial Assets
IRC §901 — IRC §901 — Taxes of foreign countries and U.S. possessions
IRC §904 — IRC §904 — Limitation on the foreign tax credit
IRS Form 1116 — About Form 1116 — Foreign Tax Credit (Individual, Estate, or Trust)
IRS Streamlined Foreign Offshore Procedures — U.S. Taxpayers Residing Outside the United States — Streamlined Foreign Offshore Procedures
IRS Form 14653 — Form 14653 — Certification by U.S. Person Residing Outside of the United States (Streamlined Foreign Offshore)
IRS — Report of Foreign Bank and Financial Accounts (FBAR), "Filing delinquent FBARs" — IRS FBAR page, "Filing delinquent FBARs": file late FBARs as soon as possible with the reason for filing late (page reviewed 30 Jul 2026)
IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (FBAR) — IRM 4.26.16.3.11 Delinquent FBAR Filing Procedures and 4.26.16.5 FBAR Penalties — the examiner standard: no penalty asserted where non-willful, reasonable cause, and the account is properly reported on the late FBAR

Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.

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