• Kasper Dahl Riis Christensen
4. semester, Revision (cand.merc.aud.), Kandidat (Kandidatuddannelse)
This project intends to describe how a company owner, through planning, can transfer his company to his offspring, resulting in the lowest possible tax. In other words, the focus in this project is generation-al change. The relevance of the project is based on studies – from SKAT, among others - which shows that up to 23,000 family-owned companies in the coming years need a generational change, without the owners having a concrete plan for this. Based on this there have been conducted an analysis of a com-pany owner's possibility to tax-free restructure his company for the purpose of generational change. These tax-free restructuring instruments is tax-free share exchange and tax-free splitting, which in con-nection with generational change, is made to facilitate the tax consequences of the transfer of a compa-ny. Furthermore, an analysis of a company owner’s possibility of transferring a company with tax-related family succession, so that the transfer does not become taxable to the transferor, but instead the transferee enters into the deferred tax liability, has been conducted. There has also been a review of the new gift fee - 7% in 2018 - if the gift is in the form of a "business". Furthermore, the so-called A/B model, which, through a combination of tax law and company law, enables a transfer of some of the company without taxation. The above-mentioned theory is used for answering a fictitious case, to de-scribe how a generational change can look in practice. The fictitious case concerns a Danish furniture factory located in “Nordjylland”, named “Design Møbler A/S”, where the company owner Ove has come to an age where the planning of a generation change will be relevant. Through the work with the theory and the answering of the case, it was concluded that there is no superior way to make a genera-tional change, but this must be done based on the prerequisites of the company and the wishes of the family. However, it has also been concluded that it is possible to individually plan and construct a gen-erational change according to the wishes that the company owner may have.
Udgivelsesdato31 maj 2018
Antal sider100
ID: 280106770