Obligatorisk national sambeskatning: En teknisk gennemgang af sambeskatningens betydning for danske selskaber med fokus på køb og salg af virksomheder

Jesper Stripp

Student thesis: Master thesis


The objective of this thesis is to address the importance of the rules on compulsory national joint taxation for Danish companies; especially in connection with acquisition and sale of companies. Companies, associations, etc with registered offices in Denmark are comprised by the rules on compulsory national joint taxation if they are part of a group. On an overall basis the group of jointly taxed companies comprises group companies or permanent establishments in Denmark. In all groups of jointly taxed companies an administration company is chosen, which is usually the ultimate parent company of the group. The main task of the administration company is to act as the group’s connection to the tax authorities. Full allocation is to be made within the group of jointly taxed companies and each individual company is only liable for that part of the tax amounts which relates to this specific company. The jointly taxed income consists of the sum of the individual companies’ taxable income and is calculated under the general rules of national tax law; with the exceptions applying to jointly taxed companies. Set-off of losses is made so that own losses must be set off before other companies’ losses can be set off. The effect of the rules on interest limitation is calculated at joint taxation level. The rules on interest limitation imply that companies may only deduct net financing expenses exceeding DKK 20.6 million provided these do not exceed 7 % of the tax base of the assets. The nondeductible net financing expenses may not be carried forward. The EBIT rule therefore means that the net financing expenses may only reduce the taxable income by a maximum of 80 %. Limited net financing expenses under the EBIT rule may be carried forward for set-off in later assessment years. Acquired companies must change their assessment years according to that of the administration company in the acquiring group. If a group relationship is changed in the course of an assessment year due to acquisition or sale of a company, the company must prepare interim financial statements at the takeover date. The main principle for preparation of interim financial statements is that these must be prepared as if covering a full assessment year. Taxes on account for companies jointly taxed at the end of the assessment year are included in full in the jointly taxed income. Upon calculation of the interest limitation, companies that have not been part of the joint taxation for the entire assessment year may only include assets at the expiry of the joint taxation period in proportion to the period of the calendar year covered by joint taxation. There is a freedom of choice in connection with calculation of EBIT. In connection with both calculations, net financing expenses must be included on an accruals basis.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2008
Number of pages89