Generationsskifte af hovedaktionærselskab

Andreas Schlichtkrull Lund

Student thesis: Master thesis


This Master thesis has been developed as part of the course in Business Economics and Auditing (Cand.Merc.Aud.) at Copenhagen Business School. The purpose of this thesis is to illustrate relevant generation shift models and principles for their use. Below the thesis will illuminate which generation shift model is most optimal for the selected case company, Byggegrossisten A/S. The main challenge in this thesis is formulated as; "What are the tax consequences for making a change in generation in Byggegrossisten A/S and how could the change in practice be implemented?"
The subject generational change is a current topic as in the coming years approx. 23.000 familyowned companies are facing a change in generation.
A generational change is a complicated process and there are many possibilities for different methods of transferring. The methods originate from a lot of different legislations and can therefore be highly incalculable to the business owner. By having a clear strategy in connection with a generation change, current and future business owners will save a lot of money as well as ensuring the future survival of the company. The other way around if the owners are too late with the transfer it may in many cases result in bad and more expensive solutions for the present and future business owner.
Throughout the thesis it has been highlighted that a generational change as a rule entails taxation in the year of disposal at the original owner. However, taxation can be postponed using tax succession. In addition, it is possible to make restructuring as part of the planning of a generational change. This will often make the change more flexible and easier compared to the wishes and requirements that the original owner as well as the new owner might have.
The conclusion in this thesis is that the most favorable transfer model for Byggegrossisten A/S will be to transfer the shares in Byggegrossisten A/S to both sons with tax succession. The tax consequences of the model will be to pay gift and share tax for a total of 2.361 However, the method does not meet the desire to keep one of the two sons out of the generational change, which could subsequently be resolved by further restructuring in Byggegrossisten A/S or by the fact that one son sells his ownership to the other son.

EducationsMSc in Auditing, (Graduate Programme) Final Thesis
Publication date2018
Number of pages86