Skattefrie omstruktureringer: Tax free restructuring according to the objective rules

Peter Andersen & Lasse Hartlev

Student thesis: Master thesis


The purpose of the task is to elucidate whether the objective rules follow the purpose of Law No. 343 and the rules applicable in practice, including assessing whether there is missing or discrepancies. We have the task of reviewing the objective rules, merger, demerger, exchange of shares and transfers of assets in order to identify differences from the system of permitted restructuring. Further, we analyze the objective rules to clarify the advantages, disadvantages and discrepancies. We conducted an empirical survey and an interview with a tax expert to support our conclusion on whether the objective rules deemed usable. We conclude the task that the purpose of the objective rules overwhelmingly are not met. The rules considered only as useful to none‚Äźcomplex company designs, because the guard rules are too restrictive and thus the risk is too great.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2008
Number of pages132