Generationsskifte: De skattemæssige overvejelser ved planlægning af generationsskifte

Abstract

The purpose of this thesis is to describe taxation of income in connection with generational transfer of personally run business and shares inter vivos causa. To ease taxation in connection with generational transfers, the Danish tax legislation provides rules which allow the assignor to transfer his business and shares while still alive without being subject to calculate capital gain. Instead the assignee enters into the assignor’s tax position so that the assignee, in the event of a later transfer, shall calculate capital gain in according with the assignor’s tax position related to the assigned asset. This entering into assignor’s position is called tax wise succession. This legislation can be used if the assignee is a close member of the family or an employee if he fulfils certain conditions.