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Law Amending The Stock Profit Tax Law, The Tax Assessment Act, Personal Tax Law And Various Other Laws And Repealing The Act On Residential Savings (Simpler Taxation Of Distributions From Mutual Funds And Expanded Access To The Utilization Of Losses From

Original Language Title: Lov om ændring af aktieavancebeskatningsloven, ligningsloven, personskatteloven og forskellige andre love og om ophævelse af lov om boligopsparing(Enklere beskatning af udlodninger fra investeringsforeninger og udvidet adgang til udnyttelse af tab ved fra

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Law on the amendment of the tax on equity, the body of care, personal tax laws and different laws, and the abolition of housing savings law

(Simpler taxation of investments from investment associations and extended access to the exploitation of losses in fraudulal taxation and other charges)

We, by God's grace, the Queen of the Danes, do our thing.

The parliament has adopted the following law, and we know that the following law has been approved by Parliament's consent :

§ 1

In the case of the tax treatment of profit and loss in the balance of shares and so on. (Asset Taxation Act), cf. Law Order no. 796 of 20. June 2011, as amended by Section 1 of law no. 624 of 14. June 2011, section 1 of law no. 1380 of 28. December 2011, section 3 of the law. 1382 of 28. December 2011 and section 9 of the law. 118 of 7. February 2012, the following changes are made :

1. Everywhere in the Act, ' investment unification certificates ` shall be replaced by : ' investment firms ' means ' investment undertakings ' means ' investment undertakings with minimum taxation `, and ' a defledling investment association ` shall be replaced by ' a UCITS with ; minimum taxation `.

2. Section 2 (2). 1, ITREAS :

" Win and loss at the encoding of winding languages from limited limited liability companies and so forth in the calendar year in which the company and so on are finally resolved shall be treated in accordance with the rules of this Act. 1. Act. however, do not apply to the encoding of winding-up rates, which are taxable for associations and companies, as provided for in section 5 B (5) of company tax. 4, and Article 12 (4) of the Merger Tax Code. 3, and in those cases where the liquidation of liquidation languages shall be as laid down in section 16 A (4) of the body of the body. 3, no. 1 shall be used for profit. In the encoding of liquidation projects from an UCITS with minimum taxation, which is covered by section 21, find 1. Act. only use, to the extent that the entrancation exceeds the minimum income, cf. Section 16 C (3) of the body of the body. 3. "

3. In the heading before section 3 and the title before paragraph 27 is changed "investment union certificates." to : "investment evidence."

4. I Section 14, paragraph 14. 1, the following shall be inserted after the ' selsanal deadline ` shall be inserted after the Article 4 (4) of the tax control Act. ONE, ONE. Pkton, ".

5. I § 14 pasted as paragraph 5 :

" Stop. 5. In the case of shares acquired in the case of a death-nest where the settlement has been submitted in accordance with the time limit laid down in paragraph 1. Paragraph 1 shall be deemed to have been laid down 1 in the case of the loading consignee at the latest, at the same time as the delivery of the settlement, shall make the person concerned in paragraph 1. 1 Provistated information for customs and tax administration. ` ;

6. In the heading to Chapter 5, the heading before section 19 and the title before section 20 is amended, "Investment association certificates." to : "Investment evidence."

7. I Section 19 (1). 2, no. 1, the Council Directive 85 /611/EEC is replaced by the following : ' Directive 2009 /65/EC of the European Parliament and of the Council.

8. Section 19 (1). FOUR, TWO. pkt., ITREAS :

' An investment firm referred to in paragraph 1. Nor does 2 comprise an account-leading association which meets the conditions of section 2, 2. and 3. a point, in the law on the taxation of members of account-leading investment associations. ` ;

9. The headline before Section 20 A is replaced by the following :

' Investment firms in UCITS with a minimum level of taxation,

Companies and others. "

10. § 20 A, paragraph 1 2, ITREAS :

" Stop. 2. For UCITS which have less than eight attendees, it is a condition for deductions that the UCITS does not invest in claims on companies which a participant in the UCITS are affiliated with ; on Article 4 (4) of the exchange rate of the court. TWO. "

11. The heading for § 21 ITREAS :

' Investment certificates in stock-based investment institutions with minimum taxation

Personnel. "

12. I Section 21 (1). 2, the ' Exiting unit ` shall be replaced by ' A UCITS with a minimum level of taxation `, and ' the ' association ` shall be replaced at three points : ' the Foundation ' s.

13. I Section 21 (1). 4, the ' investment union ' shall be replaced by ' the Foundation ', ' the Foundation ` ; ` shall be replaced by ' the Foundation ' and ` shall be replaced by ' a debt-based investment institution with minimum taxation `.

14. I Section 21 (1). 5, The 'Investment Society' is replaced by the 'Investment Institute', 'the' investment fund ', and' the 'investment institute', and 'the' exiting association 'is replaced by' an investment institution with minimum taxation '.

15. The heading for § 22 ITREAS :

' Investment certificates in debt securities-based UCITS with minimum taxation

Personnel. "

16. Section 22 (2). ONE, THREE. pkt., revoked.

17. I Section 22 (2). 2, the ' Exiting unit ` shall be replaced by ' A UCITS with a minimum level of taxation `, and ' the ' association ` shall be replaced at three points : ' the Foundation ' s.

18. I Section 22 (2). 4, the ' investment union ' shall be replaced by ' the Foundation ', ' the Foundation ` ; ` shall be replaced by ' the Foundation ', and ' a defledling stock-based investment association ` shall be replaced by ' a stock-based investment institution `.

19. I Section 22 (2). 5, The 'Investment Society' is replaced by the 'Investment Institute', 'the' investment fund ', and' the 'investment institute', and 'the' exiting association 'is replaced by' an investment institution with minimum taxation '.

20. I Section 22 (2). 6, ` ~ § 12-13 A ` shall be replaced by ' § 5 A, 12 to 13 A `.

21. I Section 23, paragraph 1. SEVEN, TWO. pkt., the following ' different income ` is inserted after ' different income ` : ` and these are shares that are not available for trade in a regulated market or registered in a securities centre '.

22. I Section 23, paragraph 1. 8, 1. pkt., ' " investment certificate ' shall be replaced by ' an investment certificate ' means a unit of investment ' to ' an investment institution with a minimum rate of taxation `, ' the investment certificate ' shall mean the ' investment certificate ' and ' assembly ` shall be ' the Foundation ' s to : ' the Foundation ' s.

23. section 24 (2). 5, revoked.

Paragraph 6 becomes paragraph 6. 5.

24. I § 27, paragraph. 1, ' The minimum income ' means the ' Council Directive 85 /611/EEC ` shall be replaced by the following : ' Directive 2009 /65/EC of the European Parliament and of the Council, and in two places the ' investment union ' shall be replaced by ' the UCITS '.

25. I § 27, paragraph. 2, no. 1, in two different places, the 'Foundation' is replaced by 'the Foundation'.

26. I § 27, paragraph. 4, the ' investment union ` shall be replaced by ' the investment capital ' shall be replaced by ' the Foundation ', ' the Foundation ' and ' Council Directive 85 /611/EEC ` shall be replaced by : ' the Foundation ' s : ' the European Parliament ' s proposal, and Council Directive 2009 /65/EC `.

27. I Section 33 (4). 1, in two parts ' association ' means the company etc : ' members ` shall be replaced by the words ' members ' and ' the company or association ` shall be replaced by : `, the company or the association ` shall be replaced by : ` ;

28. I Section 33 (4). 3, the words ' members ' shall be replaced by ' the association ', ' the association, etc. ` ; is replaced by : "the company etc.", in two places "an unloaded bond-based investment organization ' is replaced by the following :" a bond-based investment institution with minimum taxation "and" a defledling stock-based investment association 'shall be replaced by :' equity-based investment institution with minimum taxation. `

29. Section 33 (4). 4, revoked.

paragraphs 5 to 9 shall then be referred to in paragraph 1. 4-8.

30. I Section 33 (4). 5, there will be paragraph 1. 4, the words ' innuendo ' shall be replaced by ' innuendo ' ; ' paid ` shall be replaced by ' the ' loading ', ' the meaning ` shall be replaced by ' the load ', and ' the minimum load ' shall be replaced by ' the minimum level of income ' ;

31. I Section 33 (4). SIX, THREE. pkt., there will be paragraph 1. FIVE, THREE. pkt., the minimum income shall be replaced by ' minimum income '.

32. I Section 33 (4). 7, there will be paragraph 1. 6, the words ' a association ` shall be replaced by ' a UCITS or an investment institution with minimum taxation ` and ' members ` shall be replaced by ' the participants '.

33. I Section 33 (4). 9, there will be paragraph 1. 8, replaced "members of" to : "participants in", and after "or" inserts : "as members of".

34. I § 39 B pasted as paragraph 5 :

" Stop. 5. If the person at the time of fraction owned stock on which a net loss was collected, an increase can be made of the trade value of the shares that the person still owns at the time of the transfer. The increase shall be carried out with the proportion of the net loss equal to the proportion of the stock taken by the stock at the time of the relocation of the shares reached in the net loss account and remain in the person ' s possession by : The return to Denmark. "

35. The headline before paragraph 45, which has been revoked, is hereby repealed.

36. The headline before Section 45 A, which has been revoked, is hereby repealed.

37. Appendix 1 ITREAS :

' Appendix 1

Directive 2009 /65/EC of the European Parliament and of the Council

-OH,

ARTICLE 1

1. This Directive shall apply to collective investment undertakings in transferable securities (UCITS) which are established in the territory of the Member States.

2. For the purposes of this Directive and without prejudice to Article 3, the UCITS shall mean an undertaking :

a) they have the sole purpose of undertaking collective investment in transferable securities or in others in Article 50 (1). 1, mentioned liquidate financial assets of capital obtained by communication to the public, and whose business is based on the principle of risk-spreading, and

b) where units are withdrawn or deposits directly or indirectly by means of the assets of these institutions in the hands of the holders. The fact that an UCITS is taking measures to ensure that the exchange rate of its units does not differ from the net value shall be treated as such repurchase or solutions.

Member States may allow investment firms to consist of several investment departments.

3. The people in paragraph 3. The UCITS may be established under contract (investment funds managed by the management company), as "trusts" ("unit trusts"), or under the Staff Regulations (investment firms).

In accordance with this Directive :

a) the term ' investment fund ` also means the term ' unit trust ` ;

b) shares of UCITS shall also be the shares of UCITS.

4. This Directive does not cover investment firms whose assets through subsidiaries are mainly invested in other values than securities.

5. -OH,

6. -OH,

7. -OH,

-YEAH.

ARTICLE 3

The following institutions shall not be considered to be covered by this Directive :

a) closed institutions for collective investment ;

b) undertakings for collective investment providing capital without seeking to offer their shares to the public in the Community or part of this ;

c) institutes of collective investment, the units of which may be sold to the general public in third countries, in accordance with the rules of the fund or investment firms,

d) the categories of collective investment undertakings established in the provisions of the Member State in which the collective investment undertakings are established and for which the rules laid down in Chapter VII and Article 83 are the rules of the institutions ; investment and loan-absorption policy are inappropriate.

... ".

§ 2

In the case of a tax on profit by the immovable property of property (Real Estate Taxation Act), cf. Law Order no. 891 of 17. In August 2006, as amended, inter alia, section 5 of the Act of Law No, 525 of 12. June 2009, and at the latest at Article 13 of Law No 1. 1382 of 28. December 2011, the following change is made :

1. I Section 4 (4). THREE, SEVEN. pkt., and Section 5 (5). TWO, FOURTEEN. and 15. Pkt., in section 16 A (1), 6 ' shall be : ' § 16 A (3). FIVE. "

§ 3

In the law on the taxation of funds and certain associations (the Fund Taxation Act), cf. Law Order no. 1248 of 2. In November 2010, as amended by Section 7 of Law No 513 of the seventh. June 2006 and section 3 of the Law No 254 of 30. March 2011, the following change is made :

1. I Section 3, paragraph 3. THREE, TWO. pkt., in two different parts of the investment association ' shall be replaced by ' investment evidence ` and ' the investment association ` shall be replaced by the 'UCITS Institute'.

§ 4

In the Act on fusion, fission and the transfer of assets, etc. (Merger tax law), cf. Law Order no. 1260 of 3. November 2010, as amended by Section 17 of Law No 1. 516 of 12. June 2009 and section 4 of the Law No 254 of 30. March 2011, the following changes are made :

1. I § 8 (3) 8, the following rules shall be inserted after ' the rules ` : section 16 C (4) of the body. 8, ".

2. I § 14, no. 7, change the section 16 (c) of the body of the body. ONE, ONE. Whereas, in the case of the aforementioned UCITS, Section 16 C of the said UCITS shall be replaced by ' one institution ` and ' the other ' shall be replaced by ' the other ' s institution `.

3. ~ 15 a (a) (a) 4, no. 2, ITREAS :

" 2) In the case of division of the UCITS in section 16 of the body of the body, however, subject to minimum taxation, however, subject to the fact that UCITS or the receiving UCITS are an investment institution with a minimum level of taxation, as mentioned in the body of the body of the body. § 16 C. "

§ 5

In the source tax law, cf. Law Order no. 1403 of 7. In December 2010, as amended, inter alia, section 4 of the Act of Law No. 459 of 12. June 2009, section 5 of the law. 254 of 30. March, 2011, and section 5 of the law. 1382 of 28. December 2011 and at the latest at Section 11 of Law No 118 of 7. February 2012, the following changes are made :

1. I Section 2 (2). 1, no. SIX, TWO. pkt., in the form of a change in the ' outlines of the ' lodling ' unit, see to Section 16 C (3) of the body of the body. ' shall ` shall mean the ' yield from UCITS with a minimum taxation covered by Section 16 C `, ' investment union ' shall be replaced by ' the investment establishment ', and ' and derivative financial instruments according to the rules of the Finance-7 ; to : ', derivative financial instruments according to the rules of the Financial Regulation to this effect and the evidence of minimum taxation in UCITS covered by Section 16 C, which only invests in assets as mentioned in this provision '.

2. I § 49 A, paragraph. 2, no. 6, in section 16 A (1), 6 ' shall be : ' § 16 A (3). FIVE. "

3. I Section 65 (2). ONE, ONE. pkt., ' 2 h and 4 ` shall be replaced by ' 2 h, 4 and 5 (a `) and ' (b). 4 or in accordance with paragraph 1. 5 to 8 shall be replaced by the following : 3 or the consequences of paragraph 1. FOUR-SIX.

4. I Section 65 (2). ONE, TWO. pkt., the ' paragraph shall be amended 6 ` shall be replaced by the following : FIVE. "

5. Section 65 (2). ONE, FOUR. pkt., revoked.

6. Section 65 (2). 3, revoked.

Paragraph 4-8 is then being referred to in paragraph 1. 3-7.

7. Section 65 (2). 8, there will be paragraph 1. 7, repealed, and replace the following :

" Stop. 7. Investment institutes with a minimum level of taxation covered by Section 16 C of the body of the body shall contain 27% of the payment or revaluation of the yield. of the total yield, unless otherwise provided by paragraph 1. 6, 8, 11, or 13. The amount of the income contained shall be called yield tax. The provision in section 46 (3). 3, shall apply mutatis mutis.

Paragraph 8. The yield tax deduction of the yield from UCITS by minimum taxation shall be included in the section 16 C of the body of the body, which only invests in claims covered by the exchange rate law, shares in the management company which is required ; the administration of the UCITS, financial instruments of the Financial Instruments of the Financial Authority, and shall be provided for in UCITS, with minimum taxation, covered by Section 16 C, which only invests in assets as mentioned in : this provision. In addition, profit from profit from UCITS by minimum taxation shall be included in the section 16 C of the body of the body of the body of the body and investment firms, cf. Article 19 of the stock market in Article 19, if the institution of its statutes cannot be invested in shares or shares in companies in this country, other than shares in the management company that are responsible for the institution ' s administration.

Niner. 9. Investment firms, cf. company tax tenment section 3 (1). 1, no. 19, in the payment or revaluation of the yield, shall contain 27%. of the total yield, unless otherwise provided by paragraph 1. 6, 10, 11, or 13. The amount of the income contained shall be called yield tax. The provision in section 46 (3). 3, shall apply mutatis mutis.

Paragraph 10. Tax income tax shall not be included in the yield from investment firms, cf. company tax tenment section 3 (1). 1, no. 19, for investment firms, cf. Article 19 of the shareholdings of the stock of holdings in the territory of the country, excluding shares in the country, excluding shares of the management company, which shall be responsible for the company ' s administration. In addition, profit is not contained in the yield of an investment company, cf. company tax tenment section 3 (1). 1, no. 19, own stock.

Paragraph 11. 15% is contained. yield taxes on the yield of shares of shares and shares paid to investment firms, cf. the section 19 of the shareholdings of the country in which the country is situated. In addition, 15% is contained. in yield taxes on the yield of shares and shares paid to UCITS with a minimum rate of taxation, cf. Section 16 C of the body of the body in this country.

Nock. 12. An account-leading UCITS acquiring the right to yield, in which the provisions of paragraph 1 shall be regained. 3 shall not be retained by the yield tax, unless otherwise provided for in paragraph 1. 3 or the consequences of paragraph 1. 4 or 5 shall contain yields tax of the amount in accordance with the rules laid down in paragraph 1. 1, 2, 7-11 or 13. In such cases, the payment tax shall be provided for payment at the time of judicial enforcement and the provisions of section 66 shall apply mutatis mutias.

Paragraph 13. The tax minister may lay down rules on the necessary supporting documents for the holding of 15%. 0% or 0%. by paragraph 8, 2. PC, can take place. The tax minister can lay down rules that the retention of yield tax should not take place for the payment of a minimum rate of taxation, cf. Section 16C of the body. "

8. I § 67, paragraph. 6, the ' paragraph shall be amended The fourth is to : 3 ".

§ 6

In the law on the taxation of members of account-leading investment associations, cf. Law Order no. 962 of 19. September 2011, the following change is made :

1. § 2, 3. -5. pkt., is hereby repealed and the following shall be inserted :

' The proportionate returns and so on shall be made after the relationship between the person ' s afloat and the detecting of all the units in the association or department. 2. and 3. Act. shall not apply to pension taxable members. ` ;

§ 7

In the law on fiscal treatment of profit and loss of debts, debts and financial contracts (the exchange rate law), cf. Law Order no. 916 of 19. August 2011, as amended by Section 6 of Law No 1382 of 28. December 2011 and section 12 of the law. 118 of 7. February 2012, the following changes are made :

1. I Section 14, paragraph 14. 1, and § 23, 2. pkt., ' investment unifying in bonding bonds based investment foundations ` shall be replaced by : ' investment evidence in debt-based investment undertakings with minimum taxation `.

2. I Section 15 (3). 1, the following shall be inserted after the ' selsanal deadline ` shall be inserted after the Article 4 (4) of the tax control Act. ONE, ONE. Pct. "

3. I § 15 pasted as paragraph 5 :

" Stop. 5. For the claims acquired by a death-nest where the settlement has been submitted in accordance with the time limit laid down in paragraph 1. Paragraph 1 shall be deemed to have been laid down 1 in the case of the loading consignee at the latest, at the same time as the delivery of the settlement, shall make the person concerned in paragraph 1. 1 Provistated information for customs and tax administration. ` ;

4. § 34 A, paragraph. 1, ITREAS :

" If a cumulative investment association, cf. corporate tax havens in section 1 (1). 1, no. 5 a, an investment centre with minimum taxation, cf. the section 16 C of the body or an investment firm, cf. Article 19 of the asset tax system, changes the fiscal status, so that the participants are subject to the participants in a stakeholder, without the association, the Institute or the company being dissolved, the rule shall be in the section 33 (3) of the asset ' s assets. 7, similar application to the debts, debts and financial contracts of the stakeholder. `

5. I § 34 A, paragraph. 3, ' members of an investment association ' shall be replaced by ' taking part in an UCITS with a minimum level of taxation `, and ' an account ' s account ` shall be replaced by the following : ` shall be replaced by ' as members of an account ' s association `.

6. I § 38 B pasted as paragraph 5 :

" Stop. 5. If the person at the time of fraction owned claims and contracts that were collected in a net loss, an increase may be made to the commercial value of the debts and contracts which the person still owns at the time of the transfer. The increase shall be carried out with the proportion of the net loss equal to the proportion of the claim or contractual proportion of the total value of the allocation of debts and contracts concluded by the net loss account and which are still in place ; the person ' s possession at the time of the return to Denmark. If a contract is negative on the date of the transfer, no adjustment is made to the value and by setting the total value at the date of the relocation, cf. 2. pkt., the contract value for 0. Is the total value of the relocation of the two (2). Act. in the case of claims and contracts, no adjustment shall be made of the commercial value. ` ;

§ 8

In the case of the imposition of income tax to the State (body of equal pay), cf. Law Order no. 1017 of the 28th. In October 2011, as amended, inter alia, section 3 of Act 3. 624 of 14. June 2011 and Clause 1 in Act 1. 1382 of 28. December 2011 and no later than Section 5 of Act 5. 273 of 27. In March 2012, the following changes are made :

1. § 7 R revoked.

2. I § 16 A, paragraph 1 2, no. 2, change ' an investment association ` shall be replaced by ' a minimum rate of taxation ` and ' the minimum cost, cf. section 16 C (3). 2 and 13 ` shall be replaced by the following : " the minimum income, cf. section 16 C (3). 3 ".

3. I § 16 A, paragraph 1 2, no. 3, the minimum number of paragraphs 16 C (3) shall be replaced by the following : 2 or 13 ' to : ' Minimum income in accordance with section 16 C (3). 3 ".

4. I § 16 A, paragraph 1 2, no. 4, the following shall be inserted after the ' company ' shall be inserted after the ' company ' shall be inserted after the ' company ' shall be inserted after the ' company ' shall be inserted after the ' company `.

5. § 16 A, paragraph 1 4, no. 3, ITREAS :

" 3) The part of the minimum income from UCITS with a minimum rate of taxation, cf. section 16 C, referred to in section 16 C (1). 4, no. 10 if the income is received by persons, etc., which are taxable according to the section 1 (2) of the source tax of the source tax. However, the certificate of tax shall not apply where the income of the income is covered by the exchange rate of section 13 of the exchange rate. ` ;

6. § 16 A, paragraph 1 5, revoked.

Paragraph 6 becomes paragraph 6. 5.

7. I § 16 B, paragraph 1. 2, no. ONE, ONE. pkt., in the event of the issuance ' shall be replaced by : ' the acquisition '.

8. I § 16 B, paragraph 1. 2, no. 4, two places in § 16 H (4) H) 1, no. 3, and in § 16 I, paragraph 1. 1, in the case of "investment unification certificates" shall be replaced by : "investment evidence".

9. § 16 C ITREAS :

" § 16 C. An UCITS, with a minimum tax, is understood to mean an institute which issues the depositors ' deposits and who opted for the institution of the institution to be taxed in the participants. The UCITS shall make a minimum income in accordance with the rules laid down in paragraph 1. 3-8.

Paragraph 2. The evidence of an UCITS with a minimum rate of taxation or departments must justify all participants in the same proportion of the year's return on the return of each of the assets of the year or the passive in the Institute or a section thereof. The proportionate return is being done according to the relationship between the evidence and the detecting of all evidence in the department or department thereof. An UCITS can, however, be 1. Act. choose that the income must be taxed in the participants, even though they are traded or issued without the right to yield during the period from the date of the income of the income to the next date for the adoption of the yield at the time of the approval of the Foundation ; in the accounts of the previous income, where the Foundation does not actually adopt the proceeds.

Paragraph 3. The minimum income shall be the sum of income year ' s income as referred to in paragraph 1. 4 with deduction of losses in accordance with paragraph 1. 5 and expenditure pursuant to paragraph 1. 6. If an investment institution with minimum taxation ends or chooses to change the tax status, the minimum income is set up at the beginning of the income year until the time of termination or transfer to other fiscal status. Where the minimum income is to be discharged, paragraph shall be discharged. 7, 1. PC, not application.

Paragraph 4. The minimum income includes the following revenue :

1) Interest rates of interest and ongoing services are distributed over the period in which the revenue relates.

2) Remuneration for loan out of securities.

3) Officers yield after Section 16 A deduced containing profit and paid repaid tax, payment of steel after Clause 16 B and borrower's payment to the lender of his discredits on loan loans.

4) Gains of debts, cf. Article 14 (2) of the exchange rate law. 1, to the extent the winnings are not covered by No 1. 10. The charge shall be made after the exchange rate of section 26 (6) of the exchange rate of the exchange. However, the Foundation may choose to reap the benefits of all accounts in foreign currency according to the average method, cf. the section 26 (1) of the exchange rate of the court. If the average method is chosen, the institution may not later choose to make a profit after the exchange rate of the exchange rate of Article 26 (2) of the course of the exchange rate. 5.

5) W-won on debt covered by Section 6 of the exchange rate.

6) The price of financial contracts covered by the exchange rate law, section 29. The gear shall be discharged in accordance with section 33 of the exchange rate law.

7) The level of repayment of transferable securities and so on, which is subject to the tax law of the stock market, is not, however, the shares of the shares of the shares of the shares of the shares of the shares of the shares of the shares of the shares of the shares of the stock. The gear shall be discharged according to the section 25 and section 26 (5) of the shares of the asset. 2-4 and 6.

8) The price of shares, etc., covered by Section 19 of the Asset Taxation Code. The gear shall be discharged according to the section 23 (3) of the asset tax. 7.

9) Amouns referred to as a result of a lower-income minimum income, cf. paragraph 7.

10) Gains of claims in Danish kroner acquired prior to the 27th. January, 2010, and as at the time of acquisition, the minimum requirement for the exchange rate of entry of the exchange rate of Article 38, cf. Law Order no. 1002 of 26. In October 2009, loss of such claims were lost. However, losses may be dropped only to the extent that the losses do not exceed the benefits.

Paragraph 5. In the total amount of the following paragraph, 4, no. 1 9, the following losses are deducted from the following :

1) Loss of claims covered by Section 14 (4) of the exchange rate law. 1, except for losses covered by paragraph 1, 4, no. 10, and losses of debts in Danish kroner acquired prior to the 27th. January, 2010, and as at the time of acquisition, the minimum requirement for the exchange rate of Article 38 of the exchange rate shall not be fulfilled, cf. Law Order no. 1002 of 26. October 2009. For investment groups covered by company tax law's section 1 (1). 8, however, this does not apply to claims on companies with which a member of the association is the group association, cf. the section 4 of the exchange rate law where the claim is also covered by Section 4 of the exchange rate law. The loss, cf. 1. pkt., shall be collected after the exchange rate of section 26 (s) of the exchange rate of the law. The fifth paragraph is paragraph 5. 4, no. FOUR, THREE. and 4. pkt; shall apply mutatis muctis.

2) Loss of financial contracts covered by the exchange rate law, section 29. The loss is being collected according to the section 33 of the exchange rate.

3) However, losses in respect of transferable securities and so on, subject to the tax law of the stock market, are not limited to the shares of the shares of the shares of the shares of shares of the shares of the shares of shares in the field of equity. The loss shall be made in accordance with the section 25 and section 26 (5) of the asset tax. 2-4 and 6.

4) Loss of shares, etc., covered by Section 19 of the Asset Taxation Code. The loss shall be made in accordance with the provisions of Article 23 (3) of the Asset tax on the market. 7.

5) Amount made pursuant to paragraph 1. 8 as a result of a negative minimum income.

6) Amouns used for the introduction of evidence to the extent that the amount may be entered for revenues as referred to in paragraph 1. 4, no. 1-9 acquired before or as a result of the solution, cf. however, paragraph 1 9.

Paragraph 6. The UCITS may deduct the minimum income from deduction expenditure, in the amount of expenditure not exceeding any positive amount, in accordance with paragraph 1. 4, no. 1-9, and paragraph 1. 5.

Paragraph 7. The minimum income may be necpable to the nearest amount, which is a delegate by 0,10%. of the demonstrative evidence. Amount that are after 1. Act. should not be included in the minimum income, shall be produced at the minimum income of the following revenue. An acontouc fee is always collected as the actual amount paid.

Paragraph 8. A negative minimum income is produced for deduction of the minimum income in the following revenue.

Niner. 9. UCITS that are minimum taxable may choose to regulate the revenue, losses and administrative costs, cf. paragraph 4-6, which are part of the establishment of the minimum income, as a result of the issue of new evidence and the solution of evidence. If the UCITS chooses to carry out a regulation as referred to in 1. ., however, the UCITS may not deduct the income of the income year at the minimum income covered by paragraph 1. 5, no. 6. Regulation after 1. Act. is thus :

1) In the case of the issue of new evidence, the revenue, losses and administrative expenditure shall be increased until the time of emission time, which shall be taken into account for the establishment of the minimum income after the emission. The increase in revenue, loss and administrative expenditure shall be incurred in accordance with the ratio of all evidence after the mission and the imposition of all evidence before the emission. However, the loss of losses shall not occur if there is an investment association covered by the Danish company ' s corporate tax rate. 8, at the time of the loss. Corporate members, cf. Section 4 of the exchange rate law shall be taken into account in this context for one member.

2) In the case of the introduction of evidence, the revenue, losses and administrative costs shall be reduced up to the time of the time of collection, which shall be taken into account for the establishment of the minimum income after the solution. The reduction of the individual revenue, losses and administrative costs shall be incurred in accordance with the relationship between the enchanting value of all evidence after the solution and the imposition of all evidence before the solution.

Paragraph 10. Election in paragraph 1. 1 of the fiscal status of an UCITS with a minimum level of taxation must be taken before the first of the Foundation ' s revenue to which the elections are to be applied. In a newly created UCITS, the choice must be made in connection with the establishment, if it is to be applied from the first income of the Foundation. The choice has sole effect on income commencing after notification of the choice to customs and tax administration. For newly-established UCITS, cf. 2. ., however, the option may have prior effect if the notification is sent to customs and tax administration no later than three months after the establishment, but at the latest before the end of the first of the Foundation ' s revenue to which the elections will be held. The UCITS must be set within the same time limit as specified in 3. and 4. Act. submit a notification to customs and taxation on the extent to which the institute is a stock-based, cf. Asset Taxation Act, section 21, or bond-based, cf. the section 22 of the asset tax law.

Paragraph 11. The UCITS shall not, within two months of the Foundation ' s approval of the accounts, no later than six months after the end of the Foundation ' s income, provide information to customs and tax administration on the size of the minimum income and its income ; the composition and information of any difference, if the amount actually entered for the participants exceeds the minimum income. In addition, the institute must before it in 1. Act. the time limit specified in the case of customs and tax administration on the minimum income and possible value added value shall be submitted to the institution ' s income in the year to which the minimum income originates.

Nock. 12. Where there is a notification of paragraph 10 or the information provided in paragraph 1. 11 shall not be submitted in good time, the participants shall be taxed by the contestants of profit and loss of evidence in the UCITS which originate from the income years from and with the income year prior to the non-timely submission of information and subsequently the following 4 : income, according to the rules of section 19 of the asset tax law. 1. Act. shall be equally applicable if timely and correct information on minimum income and so on and the composition of it shall be provided to the securities central or financial institution and so on in this country to the parties concerned in the country, cf. the tax control Act, section 10 A, and depositary or account drivers abroad, cf. the section 11 B of the tax control officer, so that they can submit timely reporting. If, from the UCITS, there is no timely and correct information for successive successive years, the tax on the section 19 of the asset shall be retained from Section 19 from the first year of the time required for timely and correct information ; on the fourth year following the last year, which is lacking in timely and correct information.

Paragraph 13. If an UCITS with minimum taxation, cf. paragraph 1, subsequently selects fiscal status as an investment firm, cf. Article 19 of the Asset Taxation Act shall send a notification to the customs and tax administration to the customs and tax administration. The decision shall take effect on the revenue of the institution which is commended after notification of the choice of fiscal status such as investment company has been submitted to customs and tax administration. Gains and losses of evidence in the Institute which origination from the income years from and with the income of the status shift shall be subject to the following 4 incomes, are taxed according to the rules of section 19 of the shareholdings of the asset.

Paragraph 14. The tax minister may lay down detailed rules for the obligation to provide information and so on in accordance with paragraph 1. 11. "

10. I § 30 A, stk.1, nr. 2, the ' no. 10 or 12 " to : 9 or 11. "

§ 9

In the law on income tax for persons, etc. (the person tax law), cf. Law Order no. 143 by 8. February, 2011, as amended by Section 2 of Law No 554 of 1. June 2011 and Section 9 of Law No 599 of 14. June 2011, the following changes are made :

1. I Section 4 (4). 1, no. 4, the ' and 5 ` shall be deleted.

2. Section 4 (4). 1, no. 9, revoked.

Number 10-18 becomes the second paragraph. 9-17.

3. Section 4 (4). 1, no. 18, No, no. 17, revoked.

4. I Section 4 (4). 6, the ' no. 12 " to : 11 ".

5. I Section 4 (4). 7, the ' no. 10 ` shall be replaced by ' no. NINE. "

6. I § 4 (a) (a) 1, no. 1 and 2, the words ' or four ' shall be replaced by ', 4 or 5 (a `) ;

7. § 4 (a) (a) 1, no. 3, ITREAS :

" 3) taxable share profits from equity-based investment undertakings with a minimum rate of taxation, cf. Asset Taxation Act, section 21, and ".

8. I § 4 (a) (a) TWO, TWO. pkt., in section 16 A (1), 6 ' shall be : ' § 16 A (3). FIVE. "

9. I Section 13 (1). 6, in two places " no. 10 or 12 " to : 9 or 11. "

§ 10

In the law on income taxation of limited liability companies, etc. (company tax law), cf. Law Order no. 1376 of 7. In December 2010, as amended, inter alia, in section 8 of Law No 1. 254 of 30. March 2011 and section 4 of the law. 624 of 14. June 2011 and no later than Section 10 of Law No 326 of 11. In April 2012, the following changes are made :

1. I Section 1 (1). 1, no. 5 a, ' the ' defleding unit for investment `, as defined in the Section 16 C of the body of the body : ' UCITS with minimum taxation, cf. Section 16 C of the body of the law, which is investment associations `.

2. I Section 1 (1). 7, 1. pkt., change ' the ' exiting unit ` shall be replaced by ' the investment group ' s covered by the Section 16 C of the body.

3. I Section 1 (1). 8, change ' exiting investment association ' to : ' UCITS covered by Section 16 C "," profit margin for investment union "shall be changed to :" profit on the investment certificate "," encoding "shall be changed to :" Income "and" exlocussive. investment foundations ` shall be replaced by ' investment groups covered by Section 16 C of the body of the body.

4. I Section 2 (2). 1 (c) (1). pkt., in the form of a change in the ' outlines of the ' lodling ' unit, see to Section 16 C (3) of the body of the body. ' shall ` shall mean the ' yield from UCITS with a minimum taxation covered by Section 16 C `, ' investment union ' shall be replaced by ' the investment establishment ', and ' and derivative financial instruments according to the rules of the Finance-7 ; to : ', derivative financial instruments according to the rules of the Financial Regulation to this effect and the evidence of minimum taxation in UCITS covered by Section 16 C, which only invests in assets as mentioned in this provision '.

5. I Section 3, paragraph 3. 1, no. 19, 1. pkt., is changed " cf. the law on the taxation of members of account-leading investment associations, section 2, and other than the deflective investment associations, cf. Section 16 C (3) of the body of the body. 1 " to : " cf. Article 2 of the Act on the taxation of members of account-leading investment groups, except for UCITS with a minimum rate of taxation, cf. Section 16 C of the body.

6. I Section 3, paragraph 3. 1, no. NINETEEN, TWO. pkt., the following shall be inserted after ' by 15% ` : ', unless the investment company ' s own shares are dividentireed. `

7. I Section 3, paragraph 3. 1, no. 19, 3. pkt., in two places " a dissolding investment association, cf. Section 16 C (3) of the body of the body. 1 ' shall be : ' an UCITS with minimum taxation, cf. Section 16 C of the body.

8. I Section 3, paragraph 3. 1, no. 19, 5. pkt., the ' investment unifying evidence of an exce-site investment association, cf. Section 16 C (3) of the body of the body. 1 ' shall : ' shall mean investment evidence in an investment institution with minimum taxation, cf. Section 16 C of the body.

9. I Section 3, paragraph 3. 1, no. 19, 6. pkt., the ' investment association ' shall be replaced by ' the UCITS ', and the ' association ` shall be replaced by ' the Foundation ' s.

10. I § 5 F (3) 1, change the name of the company or association etc. ` ; to : "the company etf.", "company, or a association, etc." in the first place, the words ' company etc. ` shall be replaced by the following : "an investment institution with minimum taxation" means an investment association of an investment firm ' : a stock-based investment institution ; the minimum level of taxation, and "a debt-based bond-based investment association" is replaced by the following : "a bond-based investment institution with minimum taxation".

11. I § 5 F (3) 5, the words ' having a debt-based investment organization ' shall be replaced by the following : "a bond-based investment institution with minimum taxation", "a defledling stock-based investment association" shall be replaced by the following : " an investment institution with a share of equity capital, The minimum tax ',' the association 'is replaced by' the Foundation 'and' The Union's 'is changed to :' The Foundation's '.

12. ~ 13 G ITREAS :

" § 13 G. On the increase in the purchase price of an investment institute with minimum taxation, the amount of the asset tax on the purchase of the purchase order by non-effective payment of the minimum income for life assurance undertakings, even though the investment department is not an UCITS, in accordance with Directive 2009 /65/EC of the European Parliament and of the Council. ` ;

13. I Section 32 (1). 1, no. 3, in the case of "investment unification certificates" is replaced by "investment evidence".

§ 11

In the tax control law, cf. Law Order no. 819 of 27. June 2011, as amended, inter alia, in section 2 of Law No 2. 462 of 12. June 2009 and Section 19 of Law No 516 of 12. June 2009, and at the latest at Section 11 of Law No 1. 326 of 11. In April 2012, the following changes are made :

1. I Section 2 (2). TWO, ONE. pkt., in the words ' section 65 (4), 6 ` shall be : section 65 (5), FIVE. "

2. I Section 4 (4). 1, no. 1, the ' no. 10 or 12 " to : 9 or 11. "

3. I Section 7 C (3). ONE, TWO. pkt., in section 16 A (1), 6 ' shall be : ' § 16 A (3). FIVE. "

4. I § 8 X, paragraph 1 1, and two places in paragraph 3 ' Directive 85 /611/EEC ` shall be replaced by the following : ' Directive 2009 /65/EC of the European Parliament and of the Council.

5. I § 10 A, paragraph 1 2, in three different parts of the ' investment association ', ' investment evidence ` shall be replaced by the following : ' investment-proof ` shall be replaced by the following : ' The investment evidence '.

6. I § 10 A, paragraph 1 3, and Section 11 B, paragraph 1. 2, ' investment foundations ` shall be replaced by ' UCITS ` ;

7. I § 10 B (4) (b) 1, in the case of "investment unification certificates" shall be replaced by : "investment evidence".

8. Section 11 B, paragraph 1. 6, no. 5, ITREAS :

" 5) The size and composition of the minimum income from an investment centre with minimum taxation, cf. Section 16 C of the body of the body, the actual amount and the composition of any difference if the amount of the amount paid exceeds the minimum income, all in accordance with the information provided by the UCITS. ` ;

§ 12

In the area of tax-free enterprise-forming business, cf. Law Order no. 963 of 19. September 2011, the following change is made :

1. I Section 1 (1). 3, the ' no. 10 and 12 ' shall be replaced by ' no. 9 and 11. "

§ 13

In the case of the income taxation of self-employed persons (business tax law), cf. Law Order no. 1075 of 10. September 2007, as last amended by Section 11 of Law No 1382 of 28. December 2011, the following changes are made :

1. I Section 1 (1). ONE, TWO. pkt., and section 22 (a) (a) 7, 1. pkt., the ' no. 10 or 12 " to : 9 or 11. "

2. I section 22 (a) (a) 3, no. 2, the ' no. 10 and 12 ' shall be replaced by ' no. 9 and 11. "

§ 14

In the law on the assessment of the country's fixed properties, cf. Law Order no. 740 of 3. In September 2002, as amended, among other things, in paragraph 11 of Law No 1. 406 of 8. May 2006 and section 11 of Law No 514 of 7. June 2006 and at the latest at section 20 of the Act 525 of 12. In June 2009, the following changes are made :

1. I Section 33 (4). FIVE, THREE. pkt., paragraph SIX, THREE. pkt., and paragraph 7, 3. pkt., in section 16 A (1), 6 ' shall be : ' § 16 A (3). FIVE. "

§ 15

Paragraph 1. The law shall enter into force on 1. July 2012.

Paragraph 2. § 1, no. 1-3, 6, 8, 15, 17-19, 22, and 24-33, section 2, 6, section 7, no. One, four and five, eight, number. 2-9, 9, 9. 1, 3 and 6 8, section 10, section 11, no. 1, 3 and 5-8, sections 12 and Clause 14 shall have effect from 1. January 2013.

Paragraph 3. § 1, no. 4, and section 7, no. 2 shall have effect on shares of shares and claims acquired on 1. July 2012 or later.

Paragraph 4. § 1, no. 5, and section 7, no. 3 shall be effective when the settlement is delivered on 1. January 2012 or later.

Paragraph 5. § 1, no. 20 shall have effect on the abstentions of the 24th. November, 2010, or later.

Paragraph 6. § 1, no. Twenty-one, has effect from the stockholder's income 2013. For the income of the year 2013, the value at the beginning of the income of the investment firm, which will expire in the income of the shareholder, will replace the value at the beginning of the shareholder ' s income. If the shareholder's income is 2013 commenced before the first 1. July, 2012, has § 1, no. However, 21, however, will not take effect from the income of the shareholder 2014. For the income of the year 2014, the value at the beginning of the income of the investment firm which expires in the income of the shareholder is 2014, in the latter case, instead of the value at the beginning of the shareholder ' s income.

Paragraph 7. § 1, no. 34, and section 7, no. 6, has effect where move to Denmark is made on 1. July 2012 or later.

Paragraph 8. Investment undertakings with minimum taxation, cf. Section 16 C of the body of the body, cf. this law's § 8, nr. 9, by the calculation of the minimum income for the income year 2013, deduction loss of shares and financial contracts found in income year 2012 or earlier and which have not been deducied at the latest by the establishment of the minimum cost of : income year 2012, cf. Section 16 C (3) of the body of the body. 3, no. 5 and 6, in the law of law no. 1017 of the 28th. October 2011. Similarly, a negative amount shall be covered by Section 16 C (4) of the body of the body. 6, in law order no. 1017 of the 28th. In October 2011, in the year 2012 or earlier, and which has not been able to be deducied by the loss of income year 2012, the minimum income will be deduction from the income of the year 2013.

Niner. 9. If a defledling investment union before the 1. In January 2013, a decision on taxation has been decided on by Article 16 (c) of the body of law. 13, cf. Law Order no. 1017 of the 28th. In October 2011, the applicable rules have been applied in the past.

§ 16

Law on housing, cf. Law Order no. 107 of 21. February 2005, repealed.

Givet on Amalienborg, the 161. May 2012

Under Our Royal Hand and Segl

MARGRETHE R.

/ Thor Möger Pedersen