Generationsskifte og omstrukturering af familieejet selskab

Andreas Rosnell Kamp Jensen

Student thesis: Master thesis


As part of the Master of Science in Business Economics and Auditing at Copenhagen Business School, I have written this thesis as part of the final of this degree. Many Danish businesses will face a generational succession as the owner is getting closer to retirement age or other circumstances demands it. The demand of knowledge regarding a generational succession combined with new legislation has been the inspiration for this thesis. The purpose of this thesis is to address the options and consequences regarding the planning and implementation of succession regarding a family owned company within the family circle. The Danish tax-legislation is extensive and complex. The method chosen can have a large financial impact on the parties involved. This thesis strives towards enlighten advisers on these matters – and thereby addresses the laws regarding rules of succession and gift tax. The elder generation that wishes to transfer shares to the new generation, has certain needs and wishes depending on the particular situation – and likewise has the new generation. When certain requirements are fulfilled the successor can overtake the deferred tax on the transferred shares and thereby postpone the taxation of the handover. Furthermore legislation provides methods for valuation of the shares which has effect regarding the amount of liquidity essential to carry out the succession. The legislation also provides the opportunity to restructure the company which for example can change the amount of liquidity needed. Legislation also provides the possibility to transfer the shares either partly or fully as a gift to a family member. Due to change of legislation in 2017 it is now possible to make use of a reduced gift tax if the rules of succession can be met. In addition to options provided by legislation, practice provides further options when implanting a generational succession. The AB-model and “Sale-back to the issuing company” , are also addressed A successful generational succession must consider all of the above mentioned. This thesis concludes that the subject is very complex and an optimal choice of implementation very much depends on the wishes and perquisites in a particular situation.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2017
Number of pages93