Proposed 👀 Watch Compliance

Denmark: draft amendment to the VAT executive order, out for consultation and not yet issued, would take effect on 1 January 2027

This change is proposed and is not law. The rules below describe what would change if it is adopted.

This page records one dated change. For the rules in Denmark as they stand today, see the Denmark guide →

Jurisdiction
Denmark
Tax
VAT
Change type
Compliance
Status
Proposed
Impact
Watch
Announced
9 October 2026
Effective
1 January 2027
Authority
Skatte- og Vækstministeriet (Danish Ministry of Taxation and Growth)
Systems
Tax engine, Invoicing, Reporting
Verified
Fetched from official source · high confidence
Who this affects

Businesses registered in the Danish import scheme, intermediaries, and businesses buying works of art from registration-liable persons who are not resellers.

What to do

Check OSS/import-scheme registration data and art-dealer purchase invoices against the draft rules before 1 January 2027.

Tax engineInvoicingReporting

The change

Denmark's Skatte- og Vækstministeriet put out for consultation on 9 October 2026 (comments due 9 November 2026; hearing 71614) a draft executive order amending the VAT executive order (momsbekendtgørelsen), to take effect on 1 January 2027. The draft updates the executive order's EU-law footnote to cover parts of Directive (EU) 2025/516 (ViDA) and Commission Implementing Regulation (EU) 2026/1869; changes section references for the import scheme (sections 92, 117: 'section 71 e, subsections 1 and 2'); replaces the website reporting item with 'Eventuelle elektroniske websteder'; adds a duty for registrants and intermediaries to state whether they are a joint registration (fællesregistrering) under VAT Act section 47(4), with the tax agency adding the information on 1 January 2027 to existing import-scheme registrations where Denmark is the Member State of identification; and adds, in section 122(7), that businesses buying works of art from a registration-liable taxable person who is not a reseller must hold an invoice issued in accordance with section 58. It is a consultation draft, not a published order.

What changed in detail

This is a consultation draft, not a published order. Denmark’s Skatte- og Vækstministeriet put out for consultation on 9 October 2026 (comments due 9 November 2026; hearing 71614) a draft executive order amending the VAT executive order (momsbekendtgørelsen), to take effect on 1 January 2027.

The draft updates the executive order’s EU-law footnote to cover parts of Directive (EU) 2025/516 (ViDA) and Commission Implementing Regulation (EU) 2026/1869, and changes section references for the import scheme (sections 92 and 117: ‘section 71 e, subsections 1 and 2’). It replaces the website reporting item with ‘Eventuelle elektroniske websteder’. It adds a duty for registrants and intermediaries to state whether they are a joint registration (fællesregistrering) under VAT Act section 47(4), with the tax agency adding the information to existing import-scheme registrations on 1 January 2027 where Denmark is the Member State of identification. In section 122(7) it adds that businesses buying works of art from a registration-liable taxable person who is not a reseller must hold an invoice issued in accordance with section 58.

What it means

Import-scheme users and intermediaries should expect to declare their joint-registration status, and art buyers should check that invoices meet section 58. The text can change after the consultation closes on 9 November 2026.

Proof

Stk. 1. Bekendtgørelsen træder i kraft den 1. januar 2027.

Subsection 1. The executive order enters into force on 1 January 2027.

Udkast: Bekendtgørelse om ændring af momsbekendtgørelsen (høring 71614) — Skatte- og Vækstministeriet (Høringsportalen) · captured 21 October 2026
Screenshot of Skatte- og Vækstministeriet (Høringsportalen) captured 21 October 2026, showing the quoted passage Source snapshot of the official page. Open full size ↗

Sources

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