What is the aktiesparekonto and should Americans in Denmark use one?
Short answer: The aktiesparekonto is a Danish account for listed shares and equity funds, taxed annually on a mark-to-market basis at a flat rate, with an annual deposit cap set each year. For most Americans it is not worth using: the holdings inside are generally PFICs for US purposes, the account gives no US tax shelter, and the Danish flat rate saving is often clawed back by the PFIC or foreign tax credit mechanics on the US side.
Written and reviewed by Anthony Walsh, Selanis. Last reviewed 2026-10-09.
Why it works this way
Denmark lets residents place listed shares and qualifying equity funds inside an aktiesparekonto, taxed under lagerbeskatning at a flat rate rather than the ordinary, higher Danish share-income rates. The deposit cap is set and adjusted periodically, and the account is attractive to a purely Danish taxpayer because of the lower flat rate and administrative simplicity.
None of that translates for a US citizen. The account itself has no recognition in the US tax code — it is just a taxable brokerage account from the IRS's point of view. If the holdings inside are foreign funds, they are PFICs, and the Danish flat-rate tax paid does not cleanly convert into a usable US foreign tax credit because of the mismatch between Danish mark-to-market timing and US PFIC computation.
Where the account holds individually selected, non-fund, non-US company shares, the PFIC problem does not arise, but the aktiesparekonto cap is modest and most people use the account for diversified funds rather than single stocks, which is exactly where the US problem lives.
For most Americans in Denmark, ordinary brokerage exposure to US-domiciled funds — outside any Danish-specific wrapper — is simpler to report and far less likely to create a PFIC filing burden.
The expensive mistake: Opening one because a Danish colleague or bank recommended it
The account is genuinely good for a Dane. For an American it usually just adds a reporting burden (PFIC Form 8621 per holding) without a matching US benefit, since the US does not recognise the wrapper or its flat rate.
What to do
- Check what's actually held inside before assuming it's a problem — Direct shares in operating companies are not PFICs; pooled equity funds generally are.
- Compare the Danish rate saved against the US PFIC or reporting cost — The Danish benefit is often smaller than the US cost once Form 8621 and the default PFIC tax are factored in.
- Favour US-domiciled funds outside Danish wrappers where you have the choice — This generally produces cleaner, single-country tax treatment for a US citizen.