Skatteretlige omstruktureringer

Kamran Ahmed

Student thesis: Master thesis


Master’s thesis has been written as a part of MSC at Copenhagen Business School. The objective of this thesis is to clarify considerations and possibilities arising in relation to fiscal legislation restructuring and through this to recommend advantages and disadvantages of each restricting model, which includes mergers, demergers & exchange of shares. Our world is constantly changing, so does the business world. As a result of the high degree of globalization, credit crunch and know-how, should taxable restructuring provide companies the optimum business terms. Restructuring can be done either as a taxable or as a tax-free restructuring. With use of tax-free restructuring it is possible for the companies to transfer and defer the taxation to a later date. With the Bill no. 110 and 202 it is not necessary for the companies to seek permission for a tax-free restructuring. So it’s possible now for companies to make a tax-free restructuring with permission on one side and without permission on the other side. These new bills were incorporated to ease restructuring of companies, which ensure that companies will be able to meet both internal and external demands and compete in changing markets. The rules are, however, still difficult to comply with, either it’s with permission or without permission. On the basis of this thesis, it can be concluded that the choice of method for tax-free restricting depends on the company and shareholders affairs including the reasons for the transaction. Furthermore it can be concluded that the new bills has only eased the process for those companies who engage in simpler restructurings.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2011
Number of pages87