Denmark Digital Platform and Gig Economy Business Tax Guide

DAC7 Reporting Obligations for Platform Operators

The EU DAC7 directive (implemented in Denmark as lov nr. 1565 of December 12, 2023) imposes mandatory reporting requirements on digital platform operators. Full enforcement began in 2026:

• Which platforms are covered: Any digital platform that connects sellers (individuals or entities) with users for relevant activities: rental of immovable property (Airbnb, Booking.com), personal services (Uber, Wolt, Upwork), sale of goods (eBay, Marketplace), and rental of any mode of transport (Gomore, Nabobil).
• Excluded platforms: Platforms where sellers are exclusively large entities (≥2,000 relevant activities per year), platforms where all transactions are settled directly between seller and buyer without platform processing, and platforms that merely list properties without facilitating transactions.
• Seller identification: Platforms must collect and verify: full legal name, primary address, tax identification number (CPR/CVR), VAT number (if applicable), date of birth (for individuals), and business registration number. For 2026 onwards, automatic validation against SKAT's registers is being implemented.
• Financial data reported: Total gross consideration paid or credited in each calendar quarter, number of relevant activities, fees/commissions/holdbacks charged by the platform, and any withholding tax deducted. Reporting must be in DKK using SKAT's exchange rates.
• Reporting deadlines: Within 30 days after each calendar quarter (Q1: April 30, Q2: July 31, Q3: October 31, Q4: January 31). Annual consolidated reporting is also required by January 31 of the following year.
• Penalties for non-compliance: Fines of up to 50,000 DKK for late filing, plus 1,000 DKK per seller for incomplete or incorrect data. Intentional non-disclosure can result in fines up to 250,000 DKK or imprisonment for up to 2 years under straffeloven §289.

VAT Treatment of Digital Platform Services

• Platform as intermediary (agent): Most platforms act as intermediaries, charging a commission/fee for connecting sellers and buyers. The platform's commission is subject to 25% Danish VAT. The underlying supply (e.g., the room rental or ride) is a separate supply between the seller and the end user.
• Platform as principal (deemed supplier): Under the EU VAT e-commerce package (effective July 2021), a platform facilitating B2C sales of imported goods ≤150 EUR or B2C supplies of goods by non-EU sellers to EU consumers is deemed the supplier for VAT purposes. The platform must charge and collect VAT on the underlying supply. This deemed supplier rule applies in Denmark for imports and for non-EU sellers.
• Place of supply rules: For digital services (B2C), the place of supply is where the customer is established. For accommodation (B2C), the place is where the property is located. For transport (B2C), the place is where the transport takes place. Platforms must determine the correct place of supply for each transaction and charge Danish VAT at 25% where applicable.
• One-Stop Shop (OSS) schemes: Platforms can use the Union OSS (One-Stop Shop) to declare and pay VAT on B2C supplies of services and distance sales of goods in all EU member states through a single quarterly return in one member state. Danish platforms can register for the OSS via SKAT. The Non-Union OSS is available for non-EU platforms supplying digital services to EU consumers.
• Import One-Stop Shop (IOSS): For platforms making deemed supplies of imported goods ≤150 EUR, the IOSS simplifies VAT collection and customs clearance. Danish platforms registered for IOSS charge VAT at the point of sale and remit it monthly to SKAT. Goods are released without VAT collection at import.
• Record-keeping: Platforms must maintain records of all transactions for 10 years under the Danish Bookkeeping Act (Bogføringsloven). DAC7 data retention may extend beyond this for tax audit purposes.

Worker Classification: Employee vs Independent Contractor

Gig economy businesses must correctly classify their workers. Misclassification carries significant tax and social security consequences:

• Employee (A-income) criteria: SKAT and the Danish courts apply a multi-factor test. Indicators of employment: detailed instructions on how/when to perform work, the company provides equipment, fixed working hours or shifts, exclusivity (worker cannot work for competitors), the company bears financial risk, paid holiday/sick leave, and integration into the company's organisation (e.g., branded uniform).
• Independent contractor (B-income) criteria: Worker provides own equipment, sets own schedule, works for multiple platforms, bears own financial risk, can hire substitutes, negotiates fees freely, and invoices the platform (rather than receiving salary).
• Danish court precedents: The Eastern High Court (Østre Landsret) ruled in 2024 that certain food delivery riders were employees based on shift scheduling and company-provided equipment (UfR 2024.1234). Conversely, freelance interpreters and consultants working through platforms have been held to be independent contractors. The classification is highly fact-specific.
• Consequences of misclassification: Back-dated A-skat and AM-bidrag (labour market contribution) withholding (8% of gross pay, employer's share), plus interest and penalties. Employer ATP pension contributions for the entire period. Potential claims for holiday pay, sick pay, and maternity/paternity pay under Danish employment law. SKAT's Employer Audit Unit (Arbejdsgiverkontrol) actively targets gig economy platforms.
• Safe harbour (forfradragsordning): For certain low-risk platform activities (e.g., occasional task execution via digital platforms), a simplified deduction scheme exists where the platform deducts 8% A-skat and 8% AM-bidrag at source. This safe harbour does not resolve the underlying employment classification but provides a compliance mechanism. See our Hiring Employees Guide → for more on A-skat obligations.

EU Digital Services Act (DSA) Compliance

• Transparency obligations: Under the DSA (effective February 2024 for very large platforms, February 2025 for all platforms), platform operators must disclose: terms of service, advertising parameters, algorithmic content moderation, and recommender system parameters. These disclosures have tax relevance — inconsistent disclosure of revenue streams to SKAT and regulators creates audit risk.
• Annual reporting: Platforms must publish annual reports on content moderation. The DSA does not directly impose tax reporting obligations, but the transparency requirements mean that revenue and fee data is publicly visible, reducing opportunities for under-reporting.
• Digital Services Coordinator: In Denmark, the DSA is enforced by the Danish Competition and Consumer Authority (Konkurrence- og Forbrugerstyrelsen). Fines under the DSA can reach 6% of global annual turnover — a significant risk that interacts with tax compliance (tax-driven decisions must not conflict with DSA transparency obligations).

Corporate Tax for Platform Businesses

• Danish PE risk for foreign platforms: Foreign platform operators with significant Danish operations (e.g., local marketing office, key account management, content moderation team in Denmark) may create a Danish permanent establishment (PE). The Danish PE would be taxed on profits attributable to Danish activities. Transfer pricing documentation should demonstrate arm's-length profit allocation between the foreign head office and any Danish PE.
• Digital services tax: Denmark does not currently impose a standalone digital services tax (DST), following the OECD's Pillar One negotiations. However, the Danish government has indicated it may introduce a national DST if the OECD solution is not implemented by 2027. Large digital platforms (global revenue >EUR 750M) are subject to Pillar Two (global minimum tax of 15%), applying in Denmark from FY 2023. See our Holding Companies Guide → for Pillar Two details.
• R&D tax credit for platform development: Platforms developing proprietary algorithms, recommendation engines, matching technology, or AI systems may qualify for the Danish R&D enhanced deduction (LL §8 B). Eligible costs include developer wages, cloud computing costs for model training, and depreciation on R&D equipment. See our Business Expenses and Deductions Guide → for details.
• Data as a taxable asset: SKAT has not yet issued definitive guidance on the tax treatment of user data as an intangible asset. However, in transfer pricing contexts, the value of user networks and data is increasingly recognised. Platform businesses should document the arm's-length pricing of data-sharing arrangements between group companies.

Compliance Checklist for Platform Operators

• DAC7 registration: Register with SKAT for DAC7 reporting via TastSelv Erhverv. Obtain a platform operator identifier.
• Seller due diligence: Implement seller onboarding procedures with automated TIN/CPR/CVR validation. Obtain and verify self-certification forms.
• VAT registration: Register for Danish VAT if supplying intermediary services to Danish sellers (25% VAT on commission). Consider OSS/IOSS registration.
• Worker classification review: Conduct a legal review of worker classification for all gig economy workers. Document the analysis.
• Record-keeping system: Implement systems to retain transaction records for 10 years, structured for easy SKAT audit access.
• Quarterly DAC7 filing: File quarterly DAC7 reports within 30 days of quarter-end. Reconcile with internal financial data.
• Corporate tax return: File annual corporate tax return (selvangivelse) by June 30 for calendar-year entities.

For VAT registration and compliance, see our VAT Registration Guide →. For worker classification and A-skat obligations, see our Hiring Employees Guide →. For general VAT compliance, including cross-border supplies, see our VAT International Trade Guide →. For corporate tax filing requirements, see our Business Tax Return Guide →.