Invoice without VAT — when and how

Not every freelancer in Denmark is required to charge VAT. If your turnover is below DKK 50,000 per year, or if your services are inherently VAT-exempt, you can — and must — invoice without VAT. This guide explains the two main scenarios and how to handle each correctly.

Scenario 1: Under the DKK 50,000 threshold (§ 71 e)

If your total taxable turnover does not exceed DKK 50,000 within a calendar year, you are exempt from VAT registration under Momsloven § 71 e (the small-enterprise special scheme, which replaced the old § 48 in 2025). The threshold is measured per calendar year and resets every 1 January (changed 1 January 2025). You do not charge VAT, and you do not file VAT returns.

Your invoice in this case must still include: your name, address, CVR number, a sequential invoice number, the invoice date, a description of the service, and the total amount. You do not add a VAT line. Instead, add a note on the invoice indicating you are exempt.

Approved invoice note (§ 71 e): "The seller is exempt from VAT registration under the Danish VAT Act § 71 e(1) (special scheme for small enterprises), as annual taxable turnover does not exceed DKK 50,000. No VAT is therefore charged."

PennaPay adds this note automatically when you select "Private person / not VAT-registered" in the tax type dropdown.

Scenario 2: VAT-exempt services (§ 13)

Certain services are permanently VAT-exempt under Momsloven § 13, regardless of your turnover. Common examples include:

  • Healthcare services (doctors, dentists, physiotherapists, psychologists)
  • Financial and insurance services
  • Social welfare services
  • Cultural services (some specific categories)
Teaching and courses — check carefully: effective 1 January 2026, most adult, hobby, fitness and professional course teaching is subject to 25% VAT. Some education remains exempt — for example formal schooling of under-30s, and folkeoplysningsloven-funded courses at evening and folk high schools, which are treated as cultural services under § 13(1)(6). The exact boundary is narrow, so confirm your specific teaching activity with SKAT before invoicing without VAT.

If your work falls under § 13, you do not register for VAT for that activity and do not charge VAT on those invoices, even if your turnover exceeds DKK 50,000. You still need a CVR number and must issue invoices, but the VAT line is replaced with a note citing the exemption.

Approved invoice note (§ 13): "VAT-exempt supply, cf. Danish VAT Act § 13."
Note: § 13 is a broad category with many subsections — confirm with a tax adviser or SKAT's guidance that your specific service is covered. Domestic § 13-exempt supplies are actually exempt from the invoicing obligation altogether (Momsloven § 52 a, stk. 2, nr. 1), so there is no strict statutory requirement to issue an invoice or cite the section. Issuing a clear receipt that notes the exemption is still best practice for your own records and your client's.

What if you cross the DKK 50,000 threshold?

Once your cumulative taxable turnover within the calendar year exceeds DKK 50,000, you must register for VAT with Erhvervsstyrelsen. Registration must happen no later than 8 days before you begin the registrable activity — in practice, as soon as it becomes evident the calendar-year threshold will be exceeded. (The "8 days after" rule applies only to changes to an existing registration.) From the registration date, all new invoices must include 25% VAT.

Any invoices issued before VAT registration — while you were legitimately under the threshold — remain valid without VAT. You do not retroactively add VAT to them.

Invoices without VAT and your bookkeeping

PennaPay is the invoice front end of your freelance finances — not a bookkeeping system. Your bookkeeping obligation under Bogføringsloven (the Danish Bookkeeping Act, Lov nr. 700 of 24 May 2022) applies regardless of whether you charge VAT: you must keep records of all income and expenses for at least 5 years. The certified digital-bookkeeping mandate is being phased in — for personally-owned businesses it only applies from 1 January 2026, and only if net turnover exceeded DKK 300,000 in two consecutive years, so it is not a blanket requirement for every freelancer.

Export your invoices as CSV or PDF for your accountant, or sync directly to Billy if you use it for bookkeeping.

Need a template for no-VAT invoicing? → Browse 33 free Danish invoice templates
Disclaimer: This is general information about Danish VAT rules as of 2026, not tax or legal advice. Rules can differ for your situation — especially mixed-activity businesses — so check with your accountant (revisor) or SKAT before relying on it.

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