US LLC Formation From Denmark: A Complete 2026 Guide

Denmark's CFC regime requires a Danish parent to include a controlled subsidiary's income in its own taxable income when the subsidiary qualifies as a CFC — but this framework is built around Danish companies as the controlling entity, not individuals. A solo founder who owns a US LLC personally, rather than through a Danish holding company, sits outside this attribution mechanism entirely. This puts Denmark in the same family as Ireland, the Czech Republic, and Romania elsewhere in this series, where the corporate-only scope of CFC rules is exactly what makes them irrelevant to most solo-founder structures.

Denmark doesn't appear on Mercury's or Relay's prohibited-countries list, so both are workable choices for the LLC's US banking. EasyBrise's Global Launch package ($295 first year including registered agent, $149/year renewal) handles LLC formation. The EIN application for a founder without a US Social Security Number goes through the IRS's international phone line, fax, or mail process, and EasyBrise's EIN Follow-up ($129) or EIN Priority ($99) services manage that. FinCEN's 2026 final rule permanently exempts US-formed LLCs from federal BOI reporting.

Copenhagen's startup scene has grown steadily, and Danish founders building SaaS products, consulting practices, and e-commerce brands for international clients form US LLCs for the familiar reasons — USD invoicing, direct Stripe access, and a US-facing entity that's simpler to present abroad than a Danish ApS built for the same purpose. The tax picture here is more forgiving than founders often assume, once you know which rules actually apply to an individual owner.

Unlike Norway, covered elsewhere in this series, Denmark abolished its personal wealth tax back in 1997. That means a Danish founder's LLC isn't subject to any annual tax on its market value simply for existing — the aktieindkomst tax only applies when you actually receive a dividend or realize a gain, not on unrealized enterprise value sitting inside the company.

The US and Denmark have had a comprehensive income tax treaty in force since 1999, updated by a 2006 protocol that eliminated withholding on many cross-border dividend payments and tightened anti-treaty-shopping provisions. Denmark also imposes no foreign exchange controls, and — distinct from Norway's freely floating krone — the Danish krone is pegged to the euro under the EU's ERM II mechanism, giving it a notably stable, narrow trading band rather than independent float.

With CFC attribution out of the picture, what determines your Danish tax bill is how a distribution from your LLC gets taxed once you receive it. Denmark treats dividends and realized gains on shares as 'aktieindkomst' (share income), taxed on a two-tier schedule: 27% on the first DKK 79,400 in 2026 (roughly $11,500, doubled to about DKK 158,800 for married couples filing together), and 42% on anything above that. This is a genuinely different structure from the flat 15% rates seen in several other countries in this series — Denmark taxes investment income progressively, the same way it taxes almost everything else, though the 42% top rate still sits below Denmark's 55.9% top marginal rate on ordinary labor income.

Denmark does apply an exit tax if you cease to be a Danish tax resident while holding shares worth more than roughly DKK 100,000, treating the departure as a deemed disposal taxed at the same 27%/42% rates. There's a meaningful distinction worth knowing: moving within the EU or EEA lets you defer this liability without posting collateral, simply by filing the relevant form and continuing to be taxed as if still Danish-resident until you actually sell; relocating outside the EU/EEA generally requires posting collateral with the Danish tax authority (SKAT) to get the same deferral.