Denmark Business Cryptocurrency Guide

Cryptocurrency in a Danish business context triggers distinct tax rules: mining may be hobby or trading activity depending on scale, VAT is generally exempt on crypto-for-fiat exchange but taxable when crypto is received as payment for services, and crypto received as business income (vederlagsaktiv) is taxable at receipt value with subsequent gains/losses as ordinary business income.

Taxation of Crypto Mining as a Business

The landmark Supreme Court decision SKM2023.188.HR established that cryptocurrency mining, even as a hobby activity, produces taxable income. Key principles:

Hobby mining is taxable: The Supreme Court found that bitcoins obtained through mining were assets acquired for later sale as an integrated part of the taxpayer's mining activity — not private assets. Sale proceeds were taxable as business income under SL §4(a).
Professional mining is business income: If mining is conducted on a commercial scale (server farms, dedicated facilities), it constitutes trading activity (næring). All mined coins are trading assets. Income is taxed as ordinary business income at progressive personal rates or 22% corporate rate.
Electricity tax refund: Mining operations providing computing capacity (hashing power) to third parties may qualify for electricity tax refund under the "EDP bureau" practice (SKM2026.SR confirming earlier rulings). The activity is treated as electronic services for VAT purposes.
VAT on mining: The EU VAT Committee has confirmed that mining (creation, verification, validation of crypto) falls outside the VAT scope when done without direct consideration, or is VAT-exempt when done for a fee directly connected to the service.

Crypto Received as Payment for Goods/Services

When a business receives cryptocurrency as payment (vederlagsaktiv), SKAT treats it as follows:

Taxation at receipt: The crypto is valued at its market value (in DKK) on the date of receipt. This amount is included as ordinary business income in the income year of receipt.
Subsequent disposal: When the crypto is later sold or exchanged, the difference between the sale proceeds and the previously taxed value is either additional business income (gain) or a deductible business loss.
No private asset classification: Crypto received as business payment is a trading asset (omsætningsaktiv) and cannot later be reclassified as private property to claim tax-free treatment under SL §5.
VAT implications: If your business charges VAT on its services, receiving crypto as payment does not change the VAT treatment — you must still account for output VAT on the DKK value of the crypto at the time of the transaction.

VAT Treatment of Crypto Activities

The EU VAT Committee and the CJEU (Hedqvist case, C-264/14) have provided clear guidance on VAT for crypto:

Exchange crypto ↔ fiat currency: VAT-exempt as a transaction concerning "currency, bank notes and coins" under VAT Directive Article 135(1)(e). The margin (spread) earned by the exchange platform is VAT-exempt.
Exchange crypto ↔ crypto: Also VAT-exempt under the same provision.
Mining: Falls outside VAT scope when done without direct consideration. If done for a fee directly connected, it is VAT-exempt.
Storage and transfer: VAT-exempt as services "relating to transfers" under Article 135(1)(d)/(e).
Providing data capacity (hashing): Taxable as electronic services — VAT at 25% applies. This means mining farms selling hash power are VAT-taxable on that service.
NFTs: Each NFT is assessed individually. The tax treatment depends on whether the NFT represents a unique digital asset (potentially outside VAT scope) or a service/right (taxable).
Payroll tax (lønsumsafgift): A crypto exchange business selling crypto at market price plus commission is subject to payroll tax under Method 2 (financial services, 15.3%), not Method 4 (SKM binding answer).

Crypto as Employee Compensation

If your business pays employees in cryptocurrency:

Taxable as A-income: The DKK value of the crypto on the payment date is treated as ordinary salary. A-skat and AM-bidrag must be withheld and reported via eIndkomst.
Employer obligations: The same reporting and withholding rules apply as for DKK salary. The employer must convert the crypto to DKK for reporting purposes using a verifiable exchange rate.
Employer pension contributions: If the employment contract requires pension contributions, these must be calculated on the DKK equivalent of the crypto salary.

Crypto Asset Reporting Framework (CARF)

Denmark signed the OECD's multilateral CARF agreement on 15 November 2024. The framework requires crypto service providers to report customer transactions:

First reporting year: Calendar year 2026.
First exchange: September 2027.
Scope: All reportable crypto-asset transactions — exchanges between crypto and fiat, crypto-to-crypto, and transfers.
Cut-off date: Existing users distinguished from new users as of 31 December 2025.
Obligation: Danish crypto service providers must implement due diligence procedures and report to SKAT. Businesses using crypto should ensure their service providers are compliant.

For individual crypto taxation, see our Crypto Scam Loss Guide →.

Related Guides

Crypto Scam Loss Guide → — tax treatment of crypto losses
Crypto Interest/Lending Guide → — staking and lending taxation
Crypto Airdrops Guide → — airdrops and hardforks
Payroll Tax Guide → — lønsumsafgift for crypto exchanges