Denmark enacted Law No. 409 on April 29, 2025, implementing EU Directive 2023/2226 on administrative cooperation in taxation (DAC8) and the OECD's Crypto-Asset Reporting Framework (CARF), with general effect from May 1, 2025.
Crypto-Asset Reporting Framework
The law grants the Danish Minister of Taxation authority to define reporting, due diligence, and registration obligations for crypto-asset service providers. New provisions require crypto-asset service providers to identify crypto-asset users and can prevent users from conducting reportable transactions if they fail to provide required information.
Customers establishing relationships with crypto-asset service providers subject to reporting obligations must disclose their identity, including CPR numbers. The law establishes a five-year record-keeping requirement for both financial institutions and crypto-asset service providers.
Extended Common Reporting Standard
The legislation expands the Common Reporting Standard to include digital assets, central bank digital currencies, non-custodial dividends, and cross-border advance commitments. Enhanced reporting requirements now capture information on whether valid self-certifications exist and details about joint accounts, including the number of joint account holders.
For equity interests held by investment entities structured as legal arrangements, reporting must include information about the roles under which persons hold equity interests.
Administrative Cooperation
The Danish tax administration must ensure effective use of information reported under various provisions and received through information exchange under Articles 8-8ad of the administrative cooperation directive. The law introduces new reporting rules for certain cross-border tax planning arrangements and establishes penalties for non-compliance.
Most provisions take effect January 1, 2026, with electronic confirmation of tax identification numbers becoming available from January 1, 2028.
Context
The implementation aligns Denmark with updated EU and OECD transparency standards targeting crypto-assets and enhanced administrative cooperation. The phased implementation reflects the technical complexity of establishing crypto-asset reporting systems and cross-border information validation mechanisms.
