En komparativ analyse af skattereglerne for finansielle udgifter og sambeskatning, med henblik på vurdering af etablering af aktieselskab i Danmark eller aktiebolag i Sverige

Aslak Persson

Student thesis: Master executive thesis


This thesis is comparing establishment of a limited company in Denmark or Sweden, owned by a parent company in United Kingdom or the British Virgin Island. Interest, financial expenses and corporate taxation is important and relevant to consider before doing a permanent establishment with a limited company in Sweden or Denmark. Debt financing is an acknowledged, accepted and an effective way to gain capital, and utilization of tax deficit between group companies is a simple way to reduce tax payment and therefor important to use for tax planning. This thesis is comparing current tax rules in Sweden and Denmark and will guide you through relevant issues before considering Sweden or Denmark for establishment. Interest deduction in Denmark is reduced because of anti-avoidance rules with limitations by using three different set of rules; thin capitalisation rule; the interest ceiling rule; and the EBIT rule. Interest deduction in Sweden is not reduced. On the other hand, Sweden do not accept interest deduction related to closely related companies or persons. If not justified for business needs the loan will be reallocated as capital increase without interest to deduct from tax income. The Swedish state do not recognise tax deduction when a loan seems to be motivated by tax reasons and not because of business reasons. As the Swedish interest restriction rule seems to be in conflict with the EU law1 according to the commission there is an investigation looking into this, and within short time, there will be a case from the EU commission against the Swedish state. The second part of this thesis is about corporate group taxation. Denmark and Sweden both have a set of rules about corporate group taxation for limited companies, and each country has its own pros and cons depending on the situation, plans and expectations. To optimize tax payments within a corporation it is important that taxable losses is utilized and is eliminated from taxable profit. Many companies may experience losses and negative tax income before they start earning money and paying tax, and at that time it may seem less optimal that the tax deficit is restricted by the tax law. It is therefore necessary to estimate consequences and restrictions when the company has, or expect to have, a deferred tax deficit. The Danish taxation of limited companies is based on mandatory group taxation while tax payments in Sweden is executed for each separate tax income company by company. To eliminate profit and losses in Sweden the profit company perform a group contribution with deduction right and taxable for the receiving company.

EducationsMaster i Skat, (Executive Master Programme) Final Thesis
Publication date2016
Number of pages66