Skattemæssige forskelle for dansk investor af investeringer gennem kollektive ordninger i Danmark og Luxembourg

Kasper Bøgh Larsen

Student thesis: Master thesis

Abstract

This thesis will analysis if a physical person, who is fully liable to tax to Denmark, will get any tax benefits if choosing an investment opportunity from Luxembourg, compared with the same investment opportunity from Denmark. The investment opportunities which will be analysed in this thesis will be investment through a mutual fund and a pension fund. The results from the mutual funds will be compared with the taxation of investing directly in the underlying assets. The thesis will begin with a review of the Danish tax rules for capital income and equity income for physical persons. Furthermore the taxation of mutual funds and pension funds in Denmark will be reviewed and tax benefits for the different fund types will be explained. When investing through foreign funds it is necessary to understand how double taxation treaties work, which different methods for tax relief there are, how they are working and how and if funds can use the double taxation treaties. The thesis will go through these issues. The tax legislation for mutual funds and pension funds in Luxembourg will be reviewed and compared with the Danish tax law to look for differences, which could lead to variations in the effective tax rate. The reason why Luxembourg is chosen as the country to compare with is because Luxembourg is the second largest investment fund centre in the world1, and has double taxation treaties with many states. Furthermore Luxembourg is part of EU and is known for the low taxation of investments. This makes Luxembourg an ideal country to compare Denmark with, when the purpose is to find out, if it is possible to lower the effective tax rate by choosing a fund from Luxembourg instead of a fund from Denmark. When all the tax differences for investment in funds have been covered, the thesis will analysis, the impact on the effective tax rate for bonds and equities and some corporate actions from these assets. The purpose is to examine if investors obtain any tax benefit by choosing a mutual funds or pension funds from Luxembourg, and if they do, how large is the tax benefit, and what requirements is related to that.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
LanguageDanish
Publication date2013
Number of pages81