National Sambeskatning: En analyse af de gældende sambeskatningsregler.

Suzette Hansen

Student thesis: Master thesis


The purpose of my master thesis is to analyze the current rules on mandatory joint taxation from a Danish national perspective. I will begin by examining section 31C of the Danish Corporate Tax Act which lists the conditions that qualify individual companies as a group company in Denmark. The ownership percentage is not the key factor that determines whether a subsidiary qualifies. The parent company needs to have control over the subsidiary before that company qualifies as a group company. In Denmark, the income statement is generally subject to the global income principle which means that all income earned in Denmark is taxable. An exception to the global income principle is the territorial principle stated in paragraph 2, section 8 of the Danish Corporate Tax Act. The territorial principle implies that income earned by a Danish company through permanent establishment or real estate abroad shall not be assessable income for taxation purposes. The parent company is usually elected to be the administration company. The administration company settles all taxes to the tax authorities on behalf of the group. As a result, the subsidiary companies will pay their tax payable to the administration company or will receive a refund from the administration company when they are in a tax benefit position. The taxable income of the group is calculated as the sum of the taxable income from each company in the group. One of the advantages from mandatory national joint taxation is that taxable loss positions can offset a tax payable position from individual subsidiary companies within the group. The group are also able to offset tax loses from previous years with tax payables in subsequent years. Companies with a positive taxable income of DKK 7.852.500 (2016) can set off tax losses from previous year in the taxable income. Limitation rules in the use of the tax losses make sure that positive income of more than DKK 7.852.500 (2016) is only being reduced by tax losses carried forward with 60% of the income, which is higher than DKK 7.852.500 (2016). As from 1 July 2012, companies which are subject to the mandatory joint taxation rules are jointly and severally liable for the total corporation tax, withholding tax on interest, royalties and dividends.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2016
Number of pages86