Sambeskatning: En analyse af periodebegrebet

Jesper Ehlers

Student thesis: Master thesis


Since the enactment of the Danish corporation tax law in 1960 and until 2005, group taxation in Danish companies has largely been based upon some simple, basic principles that should be met in order to allow group taxation. Essentially, the parent company should own the subsidiary company 100 per cent, and both of the companies should have the same whole financial year. However, the rules of group taxation was radically modified in 2005, after which the group taxation was made mandatory for affiliated companies based in Denmark. The new rules now comply with the group concept from Danish accounting legislation, so that there is a group and therefore group taxation, if the parent company directly or indirectly owns more than 50 per cent of the capital or the votes. Furthermore there should now be group taxation, whether the group relation has existed throughout the financial year or not. This means, among other things, that a company during a financial year can be owned by two or more parent companies, when there is trade in equity holdings. Since it in these cases is required that traded companies prepare a fiscal statement of income for the subperiod, a traded company risk to determine its taxable income for several periods in the same financial year. The modified rules of group taxation have been described as the world’s most complex1, and they involve, among other things, an increased focus on the period concept of group taxation, including accruals concept and timing of establishment and terminitation of group relations. The dissertation identifies the development of Danish rules of group taxation to the current rules, as well as the structure of the existing rules. The dissertation analyses how the period concept of group taxation should be interpreted, including the extent to which jointly taxed companies should set periods for income and costs and prepare interim accounts when a jointly taxed company is traded. Both the accounting and the tax period concepts are analysed, and the dissertation concludes the differences between the period concepts and how these affect the jointly taxed Danish companies.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2009
Number of pages89