Holdingselskabers fremtid efter Forårspakken 2.0

Camilla Eriksen

Student thesis: Master thesis

Abstract

In May 2009 a new tax reform was adopted, and by that several changes in personal tax and corporate tax. This report will have a focus on a few selected areas of the tax reform, namely tax on personal income and corporate share tax. With the new tax reform comes a new definition of types of shares own by a company. They can now be parted in subsidiary shares and portfolio shares, and the shareholding will be crucial in determining which category a company shares falls under. If the shareholding is above 10%, the shares will be categorized as subsidiary shares. There is a big difference in the taxation of the two types of shares. Income (that includes capital gains and dividend income) from subsidiary shares is tax-exempt income for the pare nt company, while income from Portfolio shares is taxable income. Earlier there was a three year limit for company owned shares. If the company owned the shares for three years or more, there where no tax on the capital gain. This limit is now gone, and is the new definition of shares that determine the tax. Many companies today are owned by a holding company, with the shareholder as the ultimate owner. Holding companies are a historicai phenomenon, and many of them has been founded with the purpose of delineating activity from the operating company, and maybe investing the excess liquidity in Ion g term shares. The new tax rules for company owned shares will be of great importance for these holding companies. Another important change in company share taxation is the transition from a final taxation when the shares are sold, to a current taxation, based on the fluctuations of the share each year. This will lead to an earlier taxation than before, but also an earlier deduction, if there is a loss on the shares. The report includes different versions of financial statements for a fictitious company. The statements are made with both 2009 and 2012 tax rates, to demonstrate the effect of the new tax reform. The calculations compare how much net profit a shareholder can collect from his company each year. There are different variants of group compositions in the calculations, and both types of shares are included to exemplify the taxation of these. The report describes the new and the old tax rules for shares, and furthermore how the new tax reform affects the holding companies and their investments.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
LanguageDanish
Publication date2009
Number of pages57