Lars Enevoldsen Lundbæk

Student thesis: Master thesis


The purpose of the thesis is to find out how a generational successionis carried out in the best possible way for tax purposes, from the point of view of both the present and future owners. Before the planning of a generational successionbegins, there are a number of factors to consider. Both the younger generation, the older generation and the company must be capable before a generational suc-cessioncan be successful.Therefore, this thesis stars by analyzing, which circumstances that need to be considered, before the planning of a generational succession can begin. It is a central issue in valuationof an enterprise that it must be made within the arm`s length principles, be-cause the involved parties have a similar agenda. They both want the handover to trigger as little tax as possible. If the valuation of the enterprise is not equal to the market value, then Skattestyrelsen is author-ized to change the valuation.To make avaluation of assets or shares there have been made someguides that shouldbe used.The valua-tion methods have been examined in order to clarify in which situations each method can and should be used. Before acompany is handed overto the new generation, it must be considered whether or not there should be a reconstruction of the corporate structure before starting the generational succession. The re-construction models can be assembled in different ways, to make the optimal company structure for the generational succession. The reconstruction models have been examined and analyzed in order to assess how the models can be used together in different situations and clarify the advantages and opportunities that they provide to the generational succession. In addition to safeguarding the company's future, the main intention of a generational successionis topostponethe tax date from the date of the generational succession, so that taxation is not triggered until the younger generation sellthe shares. This can be done by the older generation transferring its shares by succession to the younger generation.The use of one or more reconstruction models combined with a transfer of shares by succession is oftenthe best way to make a generational succession. Because it allows the parties to choose if it is only a part of the company or the whole company that should be included in the generational succession so the older generation is able to keep a part of the company which at the same time will lower the price for the com-pany, so the younger generation can afford to pay for it. 2This thesis has also examined the different ways of how the generational succession can be financed. The new generation can take a loan, the transferred companycan provide the financing, the older generation can give someor the whole paymentas a gift. There is no unambiguous answer to how a generational successionis made optimally. A generational suc-cession should be planned on the basis of the parties' preconditions and desires for the future, as it is cru-cial for which restructuring models that can and should be used. Therefore, the advisor must begin by clari-fying the parties' wishes and based on that and the company's structure, evaluatethe opportunities within the specific case regarding tovaluation, restructuring and generation succession models as well as financ-ingof the generational succession.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2019
Number of pages84