Skatteplanlægning og skatteoptimering i fonde: En analyse og vurdering af de skattemæssige problemstillinger og muligheder i fonde

Kasper Lønstrøm

Student thesis: Master executive thesis


This projects is about the rules on taxation of ordinary foundations in Denmark . Taxation of foundations was changed with the tax reform from 2010 . Securities went from being taxed according to the realisation principle to be taxed according to the market-value principle. Foundations can still use the realisation principle on portfolio shares if they distribute all their entire taxable income. It is difficult to plan a zero tax in the foundations because of the new rules. This is because the foundations first now their income after the end of the taxation year. In family foundations the often at the end of the year need to say to a person that he will get a donation from the foundation and the size of the donation depend on how big the taxable income is. So the person will first get his donation after the year end. The Tax reform have made it more difficult for the foundations to get a zero-tax, but with the right planning it is still possible. Right now there is a new law on its way for the foundations. In the new law the foundations needs to have a capital on 1.000.000 dkk. instead of now 250.000 dkk. This will have that effect that many small foundations no longer need to follow the taxation rules for foundations. This will make it much more easy for the foundations.

EducationsMaster i Skat, (Executive Master Programme) Final Thesis
Publication date2014
Number of pages69