Valget af generationsskifte model: Betydningen af fremsatte lovforslag af 29. marts 2017, ’om nedsættelse af bo- og gaveafgiften ved generationsskifte’

Anne-Sofie Preisler Skau & Steffen Dige Bach

Student thesis: Master thesis


For most family owned businesses, there comes a time to start thinking about a generational handover. The considerations are many, but the choice of change model plays an upmost significant role. The purpose of the master thesis, is to highlight the impact of the impending implementation of the ‘Bill for the reduction of the tax levied on generational changes’, which implies a reduction of the current tax from 15% to 5% by 2020. This is done through analyzing, how the reduction may change the way the owner of a family held business decides, which generational change model he wants to use, when passing on to the next generation. The question is sought to be answered through a review of the succession model and the A/Bmodel, which was created by administrative practice. Furthermore, there will be used a fictional case company, to demonstrate the economic consequenses of the reductions. To demonstrate this economic consequence, two valuation methods are used to estimate the enterprise value. The models are the recognized DCF method and the rules in the circulars TSS 2000-09 and 2000-10. It appears that different results are derived by the different valuationmodels, and it is therefore concluded that there is no accordance between the valuation methods. On the basis of the valuation section, it is assumed that the tax authority will approve the values generated by the circulars. The assumption is used further to highlight the effect of the tax reduction, under the use of the two generational change models, including the consequences of a choice between the two models. Based on a proven economic impact of the bill, and the consequences taken into account, three factors are derived, respectively: the transferor's request for compensation, the liquidity required from the acquirer, and the value of the company. It is concluded that if the transferor wishes compensation, the choice of generational change model, will be the A/B model, both now and after the reduction. If, on the other hand, there are no preferences for the transferor, it is derived, based on the case company, which model would be preferable, with the assumptions taken into account. Taken to a general level, it is derived under which enterprise values, the successionmodel would be preferable, taken the bill into account. It is concluded, that the bill has an impact, when having to decide between the successionmodel and the A/B model, based on the examples in the thesis

EducationsMSc in Commercial Law, (Graduate Programme) Final Thesis
Publication date2017
Number of pages112