You work in agriculture, on livestock farms, in construction, in cleaning or in hotels, with a CPR number and tax withheld every month. Some stay for years, others come for the season. In both cases, Denmark sends the data to Bucharest, and ANAF, Romania’s national tax administration, compares it with what it knows about you.
Under Article 76(4)(o) of the Tax Code, salary received for work actually performed in Denmark and paid by a Danish employer is not taxable in Romania and is not declared here.
There are two conditions: the work is physically performed in Denmark, and the payer is a non-resident employer. The exemption does not apply in the same form to those posted by Romanian companies or to those who worked from Romania for part of the year.
ANAF starts from the data it receives automatically from Denmark and from your domicile in Romania. The result may be a notice or a decision for income tax and, sometimes, for CAS, the state pension contribution, and CASS, the health insurance contribution. A decision challenged in time and with evidence does not become final.
It is a common misconception that the Romanian tax authorities do not know what a Romanian earns abroad. Between the Member States of the Union, tax administrations automatically exchange information every year on salaries, directors’ fees, life insurance and immovable property, under Directive 2011/16/EU (DAC1). The Danish tax administration (Skattestyrelsen) therefore sends Bucharest data on the income of persons recorded with an address in Romania.
On top of this comes the OECD Common Reporting Standard (CRS): banks in more than 100 jurisdictions report the accounts of non-residents, with balances, interest, dividends and sale proceeds. In 2022, data on 111 million accounts was exchanged through this mechanism. Digital platforms report sellers’ income (DAC7), and from 2026 data on crypto-assets is also collected (DAC8).
No one has to request this data. It reaches ANAF automatically, and ANAF compares it with its own records. If you are recorded as domiciled in Romania and there is no explanation for your income from Denmark, the system generates a notice.
Almost all of them can be found in your account on skat.dk, with MitID, or you receive them from your employer. Keep them for each year.
The annual tax assessment issued by Skattestyrelsen. It shows the income and the tax determined in Denmark and is the main evidence for each year.
Payslips. They show the employer, the period worked, the tax withheld and the contributions, including ATP and arbejdsmarkedsbidrag.
The register in which employers report salaries every month. The extract shows, month by month, who paid you and how much.
Issued on request by Skattestyrelsen. The document that matters most when ANAF questions your residence.
Proof of registration in the Danish population register, with your address and date of arrival. It shows since when you have lived in Denmark.
The statement of contributions to the ATP pension. It answers Romanian claims for CAS for the same years.
Denmark treats as fully liable to tax a person who has a home in Denmark and a person who stays there for at least six months. Someone who comes for the season, for shorter periods and without a home of their own, is as a rule taxed in Denmark only on the income earned there. Romania treats you as resident if you keep your domicile or the centre of your vital interests here (Article 7(28) of the Tax Code).
When both states treat you as resident, the double tax treaty between Romania and Denmark, in force since 1977, decides the matter through its tie-breaker criteria: permanent home, centre of vital interests, habitual abode, nationality. For a seasonal worker who returns to family in Romania, residence as a rule remains here. See also dual residence.
Regulation (EC) No 883/2004 applies the social security legislation of the state in which the work is performed. For the Danish salary, contributions are paid in Denmark, including ATP, and no CAS or CASS is due in Romania on the same salary.
The Danish system funds a large part of healthcare and pensions through taxes rather than through separate contributions, so the payslip may look “empty” as far as insurance is concerned. That does not make you uninsured. The evidence is the ATP statement and, where necessary, the coordination documents issued by the Danish institutions. Workers posted by Romanian companies, with the A1 document, remain insured in Romania.
ANAF’s right to assess taxes is, as a rule, time-barred after 5 years, counted from 1 July of the year following the year for which the tax is due (Article 110 of the Tax Procedure Code). Where the obligation arises from acts that constitute criminal offences, the law provides for a 10-year period.
The decision may include income tax and social contributions, calculated as though the income had been earned in Romania, without automatically taking account of the tax and contributions paid in Denmark. What was paid there must be proved.
Interest and late-payment penalties are added for every day from the due date until payment, so the amount grows with each year reviewed.
A decision that is not appealed in time can be enforced, including by garnishment (poprire) of accounts in Romania and by measures against assets held here.
When you buy a house or make large deposits into an account, savings from Denmark may be treated as unjustified income, taxable at 70%, if their source is not proved.
I work with Romanians in Denmark without their having to come to Romania. The legal assistance agreement is signed remotely. Under a lawyer’s power of attorney (împuternicire avocațială), I represent you before ANAF and, if necessary, before the courts in Romania.
We talk by telephone, on WhatsApp or by video call, in real time, in Romanian or in English. You download the Danish documents from your account on skat.dk; I tell you exactly which ones are needed for each year.
I carry out the analysis as a lawyer, tax adviser and forensic tax expert, including the month-by-month split of the years in which you worked partly in Denmark and partly in Romania.
No. Salary paid by a Danish employer for work in Denmark is not declared and not taxed in Romania (Article 76(4)(o) of the Tax Code). Keep the årsopgørelse for each year.
For the salary, no: if it was paid by a Danish employer for work in Denmark, it is exempt in Romania. Your residence most probably remains here, but the exemption applies precisely to Romanian residents.
For the same salary, no: under Regulation (EC) No 883/2004, you are insured in Denmark, even though the Danish system is largely funded by taxes. If ANAF issues a decision, it is challenged with the Danish documents.
Do not ignore it and do not pay before an analysis. The decision is challenged within a limited period, with the årsopgørelse and the other Danish documents. Send me the decision and I will tell you on what grounds it can be challenged.
Yes. The engagement is signed remotely, I represent you before ANAF and the Romanian courts under a lawyer’s power of attorney (împuternicire avocațială), and we communicate by telephone, on WhatsApp or by video call.
Information material, updated on 3 October 2026. It does not constitute legal or tax advice; individual situations must be analysed on their own facts.
The analyses for Romanians who have moved abroad are grouped in the section Romanians living abroad, where you will also find all the countries. The general rule for salary income is explained in Working abroad, and for a specific situation see assistance for Romanians living abroad.
Italy, Germany, Spain, the United Kingdom, France, Austria, Belgium, the Netherlands, Ireland, Denmark, Sweden, the United States and Canada, the United Arab Emirates and offshore companies.
See all countriesSalary paid by a Swedish employer for work performed in Sweden is not taxed in Romania, but ANAF can issue decisions covering the last 5 years. Kontrolluppgift, slutskattebesked, SINK and a defence conducted remotely.
Read the analysisSalary paid by a Dutch employer or a temporary employment agency for work performed in the Netherlands is not taxed in Romania. Jaaropgaaf, aanslag, BRP or RNI and a defence conducted remotely.
Read the analysisSalary paid by a German employer for work performed in Germany is not taxed in Romania, but ANAF can issue decisions covering the last 5 years. Lohnsteuerbescheinigung, Ansässigkeitsbescheinigung and a defence conducted remotely.
Read the analysisSend me the notice or the decision on WhatsApp or by e-mail. I will tell you what can be challenged and which Danish documents are needed.