Generationsskifte af hovedaktionærvirksomhed

Christina Backer Thomsen & René Hedman

Student thesis: Master thesis


The purpose of this thesis is to create an overview on how a generational change of a principal shareholder company is carried out. The Danish tax-legislation is extensive and complex and the chosen method can have different f,rnancial impact on the parties involved. This thesis strives to explain when and how a generational chance is carried out most optimally. The principal shareholder that now wishes to retire has needs and wishes as does the next generation that are about to take over the company. A generational change must encompass all of fhat. Furthermore the legislation must be respected and by a case study we have examined how a generational chance can be carried out most optimally within the legal framework. The successor can under certain conditions take over the deferred tax on the shares whether the generational change is started while the principal shareholder is still alive. Tax legislation contains methods for valuation of the shares which have an effect on the liquidity needed to carry out the generational change. The legislation offers the possibility of restructuring the company which can change the need for liquidity. Principal shareholder also has the possibility to offer the successor the value of the company fully or partially as a gift. In February 2015 the govemment removed the possibility to use "formueskattekursen" which is a taxrate used to calculate and valuate unlisted shares when carrying out a generational change. Instead the shares must be valuated as were they sold to a third party on a free market which often causes a higher price. Many principal shareholder companies has unopposed that removing the special tax rate will lead to loss ofjobs because it is impossible to raise the liquidity to carry out the generational change. However in June 15 the newly elected government has planned to reintroduce this special taxrate again.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2015
Number of pages145