Generationsskifte: Generationsskifte med skattemæssig succession ved et traditionelt generationsskifte kontra en fondsløsning

Morten Roland Nielsen & Hadi Benli

Student thesis: Master thesis

Abstract

The purpose of this thesis is to describe and analyze the opportunities for a generational handover with focus on a traditional and a corporate fund solution and the consideration associated with it. The thesis will cover the subject of generational handovers of mid-sized businesses and the consideration regarding the successive tax, restructurings and financing of the generational handover.
The thesis will shed light on the benefits and consequences connected to a traditional generational handover versus a corporate fund solution. The corporate fund solution is interesting, as previously carried out analyses indicates, that the execution of traditional generational handovers of Danish owner-led businesses typically leads to negative economic consequences effecting the profit and the growth. This often is due to that few owner-led businesses survives the generational handover.
The considerations includes the decisions of selecting the optimal options for restructuring and financing connected to the generational handover between interest related parties. The thesis’s intended purpose is to compare the above-mentioned considerations with the government’s regulatory proposal of business handovers to a corporate fund done by succession without triggering any tax payments. Furthermore, the thesis will analyze the socio-economic factors that motivates a business owner in relation of the choice of which corporate structure seems optimal in connection to a generational handover of the business.
Relevant restructuring models will be selected and used to analyze a fictional business case. The business owner has already considered different possible generation handover solutions, but has not yet fully clarified how to execute the generation handover and which restructuring models that are available to wind down his business and herewith optimally prepare for a possible generation handover, as his kids have not yet showed interest for a generation handover.
With basis in the above, analyzes of restructuring models will be carried out under different scenarios to shed light on the taxation of the business handover, including the liquidity and tax challenges characterized for each restructuring model applied. Afterwards, in the light of the new governmental legislation, the thesis will include an analysis whether the business handover to a corporate fund with succession, is a beneficially alternative to the traditional business handover.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
LanguageDanish
Publication date2020
Number of pages122