EIN for Danish LLC Owners: Complete 2026 Guide

The most frequent errors: leaving line 7b of the SS-4 blank instead of entering 'Foreign' or 'N/A' for the SSN/ITIN field; assuming Denmark's CFC rules don't apply to individuals at all, when in fact a separate individual regime exists under Ligningsloven section 16 H; and confusing the flat 22% CFC rate with Denmark's much higher top progressive personal rate, which could lead to under- or over-estimating your actual exposure if CFC taxation is triggered.

If a live call doesn't suit your schedule, fax your completed SS-4 to 304-707-9471 (the line for applicants outside the US) and expect your EIN confirmation in 4 to 6 weeks. Mail to the IRS's Cincinnati processing center is also available but adds international transit time on top of the same 4-6 week window, making it the slowest realistic option.

With an EIN issued, Mercury and Relay both currently accept Denmark-based applicants for remote US business bank account opening without country-level restrictions. From there, EIN plus bank account typically unlocks Stripe, PayPal, and most US payment processors for a Danish-owned LLC. Given the control-based trigger for the individual CFC regime, it's worth having a Danish tax advisor confirm whether your specific ownership and involvement in the LLC meets the 'control' threshold before assuming either outcome.

Once your EIN is issued, a foreign-owned single-member LLC that's disregarded for US federal tax purposes must still file an annual pro-forma Form 1120 together with Form 5472, disclosing reportable transactions with its Danish owner - capital contributions, distributions, and intercompany loans included. This is purely informational when there's no US-source income, but the penalty for a missed or late Form 5472 starts at $25,000 minimum, whether or not any actual US tax was due. This runs independently of how Denmark's individual CFC rules treat the same income.

The quickest EIN route is the IRS's international applicant line, 267-941-1099, available Monday through Friday, 6:00 AM to 11:00 PM Eastern Time - which falls in Danish afternoon and evening hours given the roughly 6-hour time difference, a comfortable window compared to some other countries in this series. Have your completed Form SS-4 ready: LLC legal name, formation state and date, responsible party's name and passport number (no US SSN or ITIN needed), and a concise business-purpose description. Budget 45 to 60 minutes for the full call including hold time and the live SS-4 walkthrough with the IRS agent - a real jump from the 20-30 minutes some outdated guides still cite.

Before starting, gather: your LLC's Articles of Organization or Certificate of Formation, a fully completed Form SS-4 covering every applicable field, your passport for the responsible party identification, a US mailing address (a registered agent or virtual mailbox is fine), and a short description of your business activity. An incomplete SS-4 remains the most common reason applications get bounced back for correction.

A US LLC appeals to Danish founders selling internationally, running SaaS products, or freelancing for US clients because it's fast to set up, instantly recognized by Stripe and US marketplaces, and keeps business liability separate from personal assets in Denmark. But the LLC only becomes functional once it has an Employer Identification Number (EIN): without one, you can't open a US bank account, can't onboard a payment processor, and can't file the annual US paperwork the LLC owes even without US-source income.

Most guides to Danish CFC rules only describe the corporate version, but Denmark runs two entirely separate regimes: one for foreign companies held by Danish resident companies (Selskabsskatteloven section 32), and a distinct one for foreign companies held directly by Danish resident individuals (Ligningsloven section 16 H). If you personally own a US LLC as a Danish tax resident, it's the individual regime - not the corporate one - that applies to you, and the individual regime works differently in a way that's genuinely worth understanding before you assume the worst.

Under the individual CFC rules, taxation is only triggered if you personally control the foreign company - a threshold Danish tax authorities and case law interpret as requiring genuine decisive influence, not just any minority stake. If your LLC is caught, the good news is the rate: CFC income attributed to a Danish individual is taxed at a flat 22%, matching Denmark's corporate tax rate, rather than at Denmark's progressive personal income tax rates, which can reach roughly 52% at the top marginal bracket. Distributions the LLC pays out specifically to cover this CFC tax liability can be paid to you without additional Danish tax, which avoids a double hit on the same income.