David Munch, Ydelser

Beskatning af investeringsselskaber og aktionærer - udvalgte problemstillinger

Ugeskrift for Skat - 2010

"In 2009 the Danish parliament expanded the definition of shares that can be subject to section 19 of the Act on Taxation of Shares to comprise shares in all companies which primary business are investing in assets subject to the Act on Taxation of Shares and the Act on Taxation of Capital Gains respectively and have minimum 8 shareholders. ... This article deals with issues in connection with shares becomming subject to section 19 due to the expanded definition." (from the article (unofficial transaltion))

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Beskatning af selskabers porteføljeaktier efter lov nr. 525 af 12. juni 2009

Ugeskrift for Skat - 2009

"On 28 May 2009 the Danish parliament passed a bill according to which the taxation of portefolio shares held by companies was amended from only comprising transfers within an ownership period of three years to annual mark-to-market taxation without regard to ownership period, however the company can opt for taxation according to the realisation principle with respect to portofolio shares that are not traded on a regulated market or a multilateral tranding facility..." (from the article (unofficial translation)

 

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Incitamentsordninger - status efter lov nr. 519 af 12. juni 2009

Revision & Regnskabsvæsen - 2009

"On 28 May 2009 the Danish parliament passed a bill according to which the rule in section 7 H, subsection 2, no. 2 b) of the Tax Assessment Act concerning the tax exempt allocation of warrants (subscription rights) and options (existing shares) with a limited exercise price ("the 15 % rule") was repealed,... The time of aquisition of right to such warrants and options is decisive when determining whether these schemes can be subject to the 15 % rule.... When is the time of acquisition of right to such warrants and options?" (from the article (unofficial translation))

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