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Act On The Tax Treatment Of Gains And Losses On The Disposal Of Shares Etc. (Capital Gains Tax Act)

Original Language Title: Bekendtgørelse af lov om den skattemæssige behandling af gevinster og tab ved afståelse af aktier m.v. (aktieavancebeskatningsloven)

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Table of Contents
Chapter 1 Scope of the law
Chapter 2 The salvation of the taxable person
Chapter 3 Common shares
Chapter 4 Special rules for certain shares
Chapter 5 Investment certificates and shares in financial undertakings
Chapter 6 Loss of profit and loss
Chapter 7 Acquisitions and abstention, etc.
Chapter 8 Moto Move
Chapter 9 Entry into force
Appendix 1 Directive 2009 /65/EC of the European Parliament and of the Council

Completion of the law on the fiscal treatment of profits and losses by the loss of shares and so on. (Asset Taxation Act) 1)

This shall be allowed to act on the fiscal 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, with the changes resulting from paragraph 1 of Law No 1. 1380 of 28. December 2011, section 3 of the law. 1382 of 28. December 2011, Section 9 of Law No 118 of 7. February 2012, section 1 of the law. 433 of 16. May 2012, Section 4 of law no. 557 of 18. June 2012, section 3 of law no. 591 of 18. June 2012, section 2 of Law No 922 by 18. September 2012, section 1 in law no. 1255 of 18. December 2012, section 3 of the law. 1354 of 21. December 2012 and section 2 of the Law No 792 of 28. June 2013.

The change resulting from paragraph 1 of Law No 624 of 14. June 2011 is not the work of this legislative notice, as the change subsequently has been repealed, cf. Section 6 of law no. 1255 of 18. December 2012.

Chapter 1

Scope of the law

§ 1. The loss of shares and losses in the balance of shares shall be taken into account in the calculation of the taxable income in accordance with the rules laid down in this Act.

Paragraph 2. The rule of law relating to shares shall apply by analogs to the parties in anpartcompanies, cooperatives, transferable investment evidence and similar securities. In addition, the rules of the law shall apply mutatis muctis to the ownership shares of companies covered by corporate tax on section 2 C.

Paragraph 3. In addition, the rules of the law apply to the corresponding use of convertible bonds.

Paragraph 4. Gains and losses in the affining of the right of drawing right to the shares, the right of drawing right to convertible bonds or the right to fund assets (shares) shall be taken into account when the taxable income is charged in accordance with the rules laid down in this Act, except for section 36, in this act, however, the use of the drawing is not applicable to shares covered by Section 28 of the body of the body.

§ 2. Gains and losses at the encoding of liquidation projects from limited liability companies in the calendar year in which the company and so on end is 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.

Paragraph 2. Gains and losses in the case of a reduction in the stock market and so on in a company and so on and profit and loss at the encoding of liquidation projects from limited liability companies, etc. in advance of the calendar year in which the company and so on end is dissolved ; in accordance with the rules laid down in this law, provided that, in accordance with the rules laid down in Section 16 A, paragraph 1, 3, no. 2, has been authorised to exempt the deduction from taxation as dividends, and in cases covered by Section 16 A (4) of the body of the body. 3, no. 3.

Paragraph 3. Gains and losses by the loss of shares to the company and so on which have issued the stock shall be treated in accordance with the rules of this Act in the following cases :

1) In the case of shares acquired by the use of a purchase or drawing right covered by the body of the body of the body of the body of the body of the body of the body of the body of the body of the body of the body of the body, where the stock issue is conditional, that the stock at the time of the sale or the death of the employee is returned to the company, In that case, the obligation to acquire them shall be. However, it is a condition that the employee shareholder is not the main shareholder in the company after Section 4.

2) In the presence of an undertaking and so forth in winding-up proceedings in the calendar year in which the company and so on end is resolved, cf. However, section 16 B (4) of the body of the body. 2, no. 2.

3) On the abstention of investment evidence.

4) In the case of the sale of shares admitted to trading on a regulated market, unless the seller is sold under Article 16 B (4) of the body of the body. 3, has indicated that the sale is covered by Section 16 B (4) of the body of the body. 1.

5) When, in accordance with the body of the body, section 16 B of the equation. 2, no. 6 has been authorised to exempt the payment of the payment of taxation as a result.

6) When shares in section 17 are derived from a company that satisfies the conditions for tax-free yield in accordance with the rules laid down in section 2 (2) of the corporation tax. Paragraph 1 (c) and Article 13 (1). 1, no. 2.

Paragraph 4. Ammonies received in connection with a tax-free share exchange, cf. Article 36, or a tax-free merger or a tax free split covered by the rules of the fusion tax and which amount to a sum less than the value of each stock awarded in the receiving party, the recipient company shall be treated ; in accordance with the rules laid down in Article 16 A (1) of the equation. 1.

Translable investment evidence

§ 3. Translated investment evidence is always considered to be investment evidence that is included in trade in a regulated market.

Main Action Set Retire Definition

§ 4. As the main shareholder, shares or parties are owned by taxable who have owned or at any time in the past five years have owned 25%. or more of the share capital, or at their disposal or in the above period, the Council shall have over more than 50%. of the voting value. If the shares are acquired in relation to the conversion of a personal-owned enterprise by law on tax-free enterprise, the shareholder shall be regarded as the principal shareholder of any time during the last 10 years, owned shares corresponding to 25%. or more of the share capital at the transformation or council of more than 50%. of the voting value. In the case of the inventory of shares in a company, the company ' s holdings of own shares are suspended.

Paragraph 2. In determining whether the taxable person or the estate after the taxable owner or has owned or owned at least 25%. of the stock capital of a company or its disposal or has the Council more than 50%. in the case of the total voting value, shares held at the same time or have belonged to the spouse, parents and grandparents, children and grandchildren, and their spouses or their spouses, or to their spouses, after the persons referred to. The child's and adoptive relationship is equate with naturally kinship conditions. Activate a former spouse to the one in 1. Act. mentioned persons and shares, as a spouse to the person in 1. Act. whereas, however, the person referred to above has passed before the conclusion of the marriage. In addition, shares belonging to or have belonged to companies, funds and so on, where the persons referred to in the case of shareholder, the rule of law, agreement or joint management, has or has had a determinant influence. Determining influence on account of the stock holding shall be available if one or more persons are in the possession of 1. Act. mentioned persons, given the ownership or availability of voting rights directly or indirectly, the owner of more than 50%. of the stock capital or at its disposal more than 50%. of the voices in the company. If the shares are engaged in trade in a regulated market, the influence of a specific assessment may be carried out by an ownership share in less than 50%.

Paragraph 3. Convenance bonds shall not be included in the decision to determine whether the taxable person referred to in paragraph 1 is not included. 1 and 2 owns or have owned 25%. or more of the share capital or advises or has the Council more than 50%. of the voice value of the share capital.

Definition of subsidiary assets

§ 4 A. For subsidiary assets, stocks are owned by a company belonging to a minimum of 10%. of the shareholdings of the subsidiary, cf. however, paragraph 1 Two, three and seven.

Paragraph 2. That is a condition in accordance with paragraph 1. 1 that the subsidiary shall be covered by the section 1 (1) of the company tax tenment. 1, no. 1-2 a, 2-d and 3 a-5 b, or that the tax on profits from the subsidiary company shall be waived or reduced in accordance with the provisions of Directive 2011 /96/EU on a common taxation system for the mother and subsidiaries of different Member States or after a double-tax agreement with the Faroe Islands, Greenland or the State in which the subsidiary is established.

Paragraph 3. The data company assets shall be deemed to have been owned directly by the direct and indirect shareholders of the parent company, which are covered by the section 1, section 2 (2) of the company tax liability. 1 (a) (a) or § 31 A or 32, the Danish Fund Code, section 1 or of the body of the Pension Act, section 16 H, which shall be the owner of at least 10% of the shareholder ' s shareholder and the intermediary. of the share capital of the underlying company. However, this only applies if the following conditions are all met :

1) The primary function of the intermediate holding company is ownership of subsidiary assets and corporate assets, cf. § 4 B.

2) The interchange company does not carry out any real economic activity relating to the ownership of the stock.

3) The company owner does not own the entire share capital of the subsidiary, or the interchange company owns the entire share capital of a subsidiary that is not taxable in Denmark and where the tax on profits from the subsidiary network is directly responsible for the business of the subsidiary undertaking ; Ownership would not have to be reduced or dropped according to the provisions of Directive 2011 /96/EU on a common system of taxation for the mother and subsidiaries of different Member States or by a double-tax agreement with the Faroe Islands, Greenland or the State in which the subsidiary company is based.

4) The shares of the interchange party are not available for trade in a regulated market or a multilateral trading facility.

5) More than 50%. of the share capital of the intermediary company, directly or indirectly of undertakings, etc. as mentioned in 1. pkton, which would not be able to receive yields tax freely by direct ownership of the shares of the individual subsidiary.

Paragraph 4. If the same shares are in the same shares as paragraph 1. 3 is directly owned by several corporate shareholders covered by paragraph 1. THREE, ONE. pkt., is the stock is considered to be owned directly by the top shareholder.

Paragraph 5. If the stock is owned by corporate shareholders as referred to in paragraph 1. 3, no. 5 shall be added to the yield of yield, to be taken into account in the balance sheet, in the balance sheet, in the case of the inventory. 3, no. 5 :

1) holdings belonging to personal shareholders with a determinant influence, cf. Section 16 H (3) of the body of the body. Six, in the corporate shareholder.

2) Persons belonging to persons who are close to the personal shareholders, cf. Section 16 H.

3) Portfolio holdings belonging to companies, etc., where the person group referred to in paragraph 1 shall be subject to the number of persons concerned. 1 and 2 determine the influence, cf. Section 16 H (3) of the body of the body. 6.

4) Portfolio holdings belonging to funds and so on by the person group referred to in paragraph 1. 1 and 2, cf. Section 16 H (3) of the body of the body. 6.

Paragraph 6. In the case of the retention of yield tax, according to the section 65 of the source tax rate, in case of a corporate shareholder in accordance with paragraph 5. 3 shall be deemed to own shares in underlying companies directly, the company ' s undertaking for payment of an amount equal to the tax value of the company shareholder ' s share of the extracted dividends to the intermediate holding company. The payment has no tax consequences for the paying or the recipient.

Paragraph 7. Data company assets, cf. paragraph 1, does not include convertible bonds and drawing dishes for convertible bonds.

Definition of corporate assets

§ 4 B. For corporate assets, the shares in which the owner and the company in which shares are owned are co-taxed according to section 31 of corporate tax and tax collec; s, by corporate tax, and in the case of corporate assets, shares are defined in the Community ; a fund and so on and the company in which shares are owned are conglomnities, cf. " corporate tax havens " section 31 C and where the company may be included in a tax on taxation.

Paragraph 2. Corporate assets shall be deemed to have been owned directly by the shareholders of the owning company ' s shareholders, which are covered by the section 1, section 2 (2) of the corporate tax. 1 (a) (a) or § 31 A or 32, the Danish Fund Code, section 1, or equal to 16 H, which owns at least 10% of the Fund. of the share capital of the underlying company in any link between the shareholder and the interchange party. However, this applies only if all the conditions in section 4 A (1) are applied. 3, no. 1-5, have been met. § 4 A, paragraph 1 4-6, shall apply mutatis muth.

Paragraph 3. Corporate enablers, cf. paragraph 1, does not include convertible bonds and drawing dishes for convertible bonds.

Tax Free Portfolio Retire Definition

§ 4 C. In the case of tax-free portfolio, stocks are not available for trade in a regulated market or a multilateral trading facility owned by a company and so on which owns less than 10%. of the share capital of the portfolio company, cf. however, paragraph 1 2-5.

Paragraph 2. Tax-free portfolio stock does not include shares owned by a life assurance undertaking.

Paragraph 3. It is a condition that shares are covered by paragraph 1. 1 that the portfolio company is an equity or anpartcompany which is taxable according to section 1 (1) of the company tax havens. 1, no. 1, or a similar foreign company.

Paragraph 4. It is a condition that shares are covered by paragraph 1. 1 that the value of the portfolio of the portfolio of shares available for trade in a regulated market or a multilateral trading facility, discharged on average over the preceding financial year for the portfolio of the portfolio does not exceed 85%. of the portfolio company ' s own funds at the end of the same financial year. However, for the initial financial year of the portfolio, the first accounts shall be the basis of the inventory. If the portfolio of portfolio determines the influence of the portfolio, cf. Section 2 (2) of the body of the body. 2, over another company whose shares are not available for trading in a regulated market or a multilateral trade facility, shall be seen in the calculation after 1. Act. aside from these shares, and instead include the shares of the other company ' s shares included in trade in a regulated market or a multilateral trade facility, and own funds equivalent to the portfolio of the portfolio directly or indirectly ; ownership of the other company.

Paragraph 5. Tax-free portfolio tactics do not include shares covered by sections 4 A and 4 B, convertible bonds, or drawing-courses for convertible bonds.

The FIFO principle

§ 5. Where a taxable person owns shares with the same rights acquired at different times, they shall be deemed to have acquired shares only for the first supposed reasons.

Paragraph 2. Stocks in accordance with section 7 A of the body count shall be taken into account in accordance with paragraph 1. 1 from the date on which the tape is terminated. 2)

Tab

§ 5 A. Loss of loss of shares can be deducted only to the extent that the loss exceeds the sum of the following yields :

1) Received yields of the shares in question, which the taxable owner has been exempt from the income of the income.

2) Received yields of the shares in question, where the taxable person has achieved relief for profit-making charges after a double-tax agreement with a greater amount than the tax paid to the foreign state. An amount equal to the increase in relaxation shall be counted.

Paragraph 2. The sum of yields received in paragraph 1. 1 shall be increased to the extent to which the taxable of the benefits provided for in the company concerned has received equivalent yields which have not already reduced loss-deduction in accordance with paragraph 1. 1.

Paragraph 3. Companies which are taxable in accordance with section 17 or are covered by Section 43 (3). 4, shall be the sum of yields received in accordance with paragraph 1. 1 include all grants and dividend of profit-preferential benefit granted by the company-giving corporate corporation and group companies which directly or indirectly affect, directly or indirectly, to the other ; corporate companies which are not directly or indirectly influencing by the company-giving group. Corporate companies shall include companies in the same group, after company tax, section 31 C. 1. Act. the corresponding use shall apply to persons who are taxable in accordance with section 7, if these directly or indirectly affect both the subsidy and the receiving company of the grant.

Chapter 2

The salvation of the taxable person

Companies and other things.

§ 6. Companies, foundations and associations, etc., which are taxable according to corporation tax law or the tax burden on the taxable income, shall, in the calculation of the taxable income, include the profit and loss of shares covered by sections 1 and 2 in accordance with the rules which are : specified in sections 5, 8-10 and 16-19, section 20, section 20. 1, section 20 A, Chapter 6 and § § 29 A-31, 33, 36-37 and 43.

People

§ 7. Persons taxable according to the source tax law and the taxable income of the death penalty tax shall, in the calculation of the taxable income, include the profit and loss of shares covered by sections 1 and 2 in accordance with the rules which are : specified in section 5, section 12 to 15, Chapter 4, section 19, section 20, section 20, section 20, section 20. 2, sections 21 and 22, Chapters 6 and 7, sections 37-39 B and 44-47.

Chapter 3

Common shares

Data company assets, corporate assets and tax-free portfolio tactics

Companies and other things.

§ 8. Gains and losses in the abstention of subsidiary assets, corporate assets and portfolios shall not be included in the inventory of the income of the taxable income.

Taxable portfolios, etc.

Companies and other things.

§ 9. 2) The profit of shares not covered by Article 8 shall be taken into account when the taxable income is charged, cf. however, section 10.

Paragraph 2. Loss of shares covered by paragraph 1 1, where the taxable person uses the storage principle, cf. Section 23, paragraph 1. 5, deductory from the deducisation of the taxable income, cf. however, paragraph 1 5 and section 10.

Paragraph 3. Loss of shares covered by paragraph 1 1, where the taxable person applies the principle of application, cf. Section 23, paragraph 1. Paragraph 6 may be deduced from the profits of the income year in accordance with paragraph 1. 1, cf. however, paragraph 1 5 and section 10.

Paragraph 4. Loss not deduable from paragraph 1. Paragraph 3 shall be deduced from the profits of the following income in accordance with paragraph 1. 1. Loss can only be transferred to deduction in future income if it cannot be spatial in net gains on the subject of a profit-based stock subject to paragraph 1. 1 in an earlier income. In the changeover to the storage principle, losses may be deduced in net winnings covered by paragraph 1. 1.

Paragraph 5. Notwithstanding paragraph 1 2 and 3 may lose the loss of group-internal convertible bonds and drawing courses for such convertible bonds shall not be deducted from the inventory of the income of the taxable income. In the group ' s internal convertible bonds, bonds are the bonds of corporate affiliates, cf. corporate tax havens, section 31 C.

§ 9 A. (The case).

Own shares

Companies and other things.

§ 10. The profit and loss of own stock shall not be included in the inventory of the income of the taxable income.

Mergers between cooperatives and companies and so on.

Companies and other things.

§ 11. (The case).

Gains

People

§ 12. The balance of shares shall be taken into account in the calculation of the income of the taxable income.

Loss shares not included in trade in a regulated market

People

§ 13. Loss of loss of shares that are not available for trade in a regulated market shall be deducted from the deduction of the income of the taxable income.

Paragraph 2. Paragraph 1 shall not apply to shares which have been engaged in trade in a regulated market within the owner time of the taxable age. Loss of such shares shall be taken instead of section 13 A.

Loss shares admitted to trading in a regulated market

People

§ 13 A. Loss of loss of shares admitted to trade in a regulated market is deducted from the sum of the profits of the income year, gains and steel of the same amount of the equal rights of Section 16 B, cf. However, this is Section 14 of the law. However, losses may only be deductible in yields, gains and abstentions relating to shares relating to trading in a regulated market where a possible benefit is covered by section 12, and in yield for shares relating to shares covered by Section 44. In addition, losses can be deductible only in yields, gains and abstentions, that are share income, cf. pager, section 4 a.

Paragraph 2. Loss not deduable from paragraph 1. 1, from the following income years yields, gains and abstentions, after the body of the body of the body, section 16 B. B. 1, 2. and 3. pkt; shall apply mutatis muctis. Loss can only be transferred to deduction in future income, provided that it cannot be spaced in the sum of profits, gains and abstentions in an earlier income.

Paragraph 3. is the taxable duty and exceeds the total loss of the sum of total yields, gains and abstentions in accordance with section 16 B of the body of the body, the excess amount in the income year for deduction in the net amount of the spouse shall be transferred. total yields, gains, losses and abstentions, in accordance with the section 16 B of the body of the body, if the spouses are at the end of the income year, cf. the section 4 of the source tax code. The loss is also transferred after the rule in 1. Act. for the net amount of the net amount of the total yields, gains, losses and loss of steel in accordance with the provisions of the Section 16 B of the following income, if the loss cannot be contained in the sum of the yields, gains and abstentions ; in accordance with the section 16 B of that product concerned. Paragraph 1, 2. and 3. pkt; shall apply mutatis muctis.

§ 14. Deduction after section 13 A is conditional on customs and tax administration prior to the expiry of the sellection period following the provisions of section 4 (4) of the tax control Act. ONE, ONE. on the basis of the income in which the acquisition has taken place or where the shares of shares taken pursuant to the Section 7 of the body of the body are terminated, information on the acquisition of shares with an indication of the asset ' s identity, the number, has been obtained ; the time of acquisition and the sum of the purchase of the purchase.

Paragraph 2. The conditions of paragraph 1. 1 shall be deemed to be fulfilled if the customs and tax administration, irrespective of the time limit laid down in paragraph 1, 1 has received information on the acquisition by reporting from other reporting obligations other than that of the taxable person on the basis of Article 10 (1) of the tax control Act. 4, § 10 B, § 10 E or § 11 H. Condition in paragraph 1. Paragraph 1 shall also be deemed to be fulfilled if the taxable person may demonstrate that the reports which have been made on behalf are incorrect.

Paragraph 3. The condition laid down in paragraph 1 shall be deemed to have been paid for the stock acquired prior to the withdrawal of the tax. 1 in the case of the loss-making share included in the declaration in accordance with the tax audit Act, Section 11 B (1). 4, or if the forgiving share is part of the information contained in a summary containing the information referred to in section 11 B (b) of the tax control Act. 4, on the ownership of shares in the event of the withdrawal of tax duties to the country to which the taxable person has submitted customs and tax administration to the country of departure for that income, where the tax duty is here for the country to take place. For shares that are included in a inventory view, cf. Section 39 A shall be deemed to have been laid down in paragraph 1 shall likewise be fulfilled.

Paragraph 4. In the case of shares in the owner time of the taxman who are admitted to trade in a regulated market without any prior commitment to trade, the condition referred to in paragraph 1 shall be deemed to have been placed under the market. 1 in the case of the receipt of information relating to the acquisition of the asset before the expiry of the self-demart grid, where the stock is entered for trading on a regulated market, The condition of 1. Act. shall be deemed to have been met if customs and tax authorities have received information on the possession of the possession of Article 11 B (b) of the tax control Act. 6, or any time limit in 1. Act. has received information about the possession of a report pursuant to Article 10 (10) of the tax control Act. 1 and 2, or the information provided for in Article 11 B (B) of the Tax Code. Number two, two, two. pkt; shall apply mutatis muctis.

Paragraph 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.

Asset with Boligret

People

§ 15. Loss and loss of shares, cooperatives and similar securities associated with the right to a residential apartment in a property with several residences are tax-free when the housing requirement, and so on, is subject to the housing requirement. the property of the property tax on Article 8 (8). Four is fulfilled.

Paragraph 2. Gains and losses at the extraction of liquidation projects of shares and so on as provided for in paragraph 1. 1 shall be taxless under the same conditions as referred to in paragraph 1. 1 where the encoding takes place during the calendar year in which the company and so on end is dissolved.

Chapter 4

Special rules for certain shares

Allocation of the drawing-up of the stock-hitherto shareholders

Companies and other people

§ 16. The drawback of drawing up the drawing-line shares as a result of the allocation of drawing-ins to shares not proportionate to the shareholders to date are tax-free. Loss of loss of drawing corrective action as referred to in 1. Act. cannot be dedudiable.

Paragraph 2. Notwithstanding the rules of paragraph 1 1 the profit and loss shall, however, be taken into account in the calculation of the taxable income, provided that the award is a gift to the recipient. Rule of 1. Act. shall apply only to the allocation of drawing dishes that give the right to a stock drawing of shares at a rate at the time of the award being below the market rate.

Approach

Companies and other people

§ 17. If the taxable person is in charge of buying and selling shares, profit and loss shall be paid by the loss of shares acquired as part of this nutrient road, by the calculation of the income of the taxable income.

Paragraph 2. Notwithstanding paragraph 1 1 may result from the loss of group-internal convertible bonds and the drawing-up of such convertible bonds not deducted from the deduction of the taxable income. In the group ' s internal convertible bonds, bonds are the bonds of corporate affiliates, cf. corporate tax havens, section 31 C.

Paragraph 3. Where the taxable person shall be subject to paragraph 1. 1, the benefits or losses of all the tax-duty investment shall be included in UCITS with a minimum rate of taxation, cf. Section 16 C (3) of the body of the body. 1, by the calculation of the taxable income.

Paragraph 4. In cases covered by paragraph 1, 1 or 3, the rules in section 8, 9, 12-14, 17 A, 22, 44 and 47 shall not apply. paragraphs 1 and 3 shall not apply in the sections 10 and 15, section 16 (4). 1, and sections 18 and 19 cases.

Assets Owned by Capital Fund Partners

People

§ 17 A. In the case of taxable persons with a preferential position in a capital or refundment, profit and loss of shares acquired through the capital or venture fund in the calculation of the income of the taxable income. The benefits will also be paid for profits and dividends on the stock. The taxable person shall have a priority when it has been agreed that the proportionate share of the investment unit result in the investment unit exceeds the proportionate share of the total amount of participation by the tax obligation. The total amount of participating funds shall cover both the deposit capital and the loan capital have been deposited by participants in the capital and venture fund.

Paragraph 2. Gets by paragraph 1 must be divided into

1) gains that do not exceed a standard yield, cf. paragraph 4, of the deposited capital, and

2) benefits that exceed the default return of the deposit capital.

Paragraph 3. In the case of capital and venture funds, investment units which are investing in shares for the purpose of wholly or partially acquiring one or more companies, etc., with a view to taking part in management and operation of these.

Paragraph 4. The yield of the other participants in the capital and venture without preferential treatment will mean the return of the draft. In the calculation of the standard yield, both the yield of the deposit capital and the yield of the loan capital are taken into account.

Paragraph 5. In cases covered by paragraph 1, 1 shall find the rules in sections 12 to 15, 22, 44 and 47 not applicable. Paragraph 1 shall not apply to the provisions of section 16 (3). One, and sections 17, 18 and 19 cases.

Parts in cooperatives

Companies and other people

§ 18. Gains and losses at the abstention of cooperatives or shares in cooperatives covered by section 1 (1) of the corporation tax liability. 1, no. 3, shall be taken into account in the calculation of the income of the taxable income.

Paragraph 2. Gains and losses in the encoding of liquidation projects from cooperatives referred to in paragraph 1. 1 shall be included in the calculation of the income of the taxable income during the calendar year in which the co-operation is finally dissolved.

Paragraph 3. In cases covered by paragraph 1, Paragraph 1 or paragraph 1. 2, find the rules in section 9, 12-14, 17, 17 A, 19, 31, 32, 36 and 47 not applicable.

Paragraph 4. The first subparagraph shall not be subject to paragraph 1 of paragraph 1. One and three, if the co-op board is set before the 22nd. In May 1987 and the abstention have not been taken to avoid taxation following paragraph 1. 2.

Chapter 5

Investment certificates and shares in financial undertakings

Investment certificates and shares of investment firms

Companies and other people

§ 19. The profit and loss of shares and investment certificates, etc. issued by an investment firm, shall be taken into account in the calculation of the income of the taxable income.

Paragraph 2. For the purposes of an investment company :

1) An UCITS according to Directive 2009 /65/EC of the European Parliament and of the Council, cf. Annex 1.

2) A company, etc., whose business consists of investment in transferable securities and so on, and where shares in the company are required to withdraw from the assets of the company ' s assets to an exchange value which is not significantly less than the internal market ; value. On the basis of withdrawal, a third party signers to the company that either the person concerned or any other natural or legal person on request will buy any share of a courier value that is not substantially less than the internal one value. The requirement to withdraw the request is fulfilled, even if the requirement is only met within a certain period. Regardless of the duty to repurchase, the company shall be deemed to have a collective investment in transferable securities and so on by collective investment, the company shall have at least 8 participants. Concerns and attendees, cf. Section 4 (4) of the exchange rate law. 2, and section 4 (4) of this Act. 2 is considered in this context for one participant.

Paragraph 3. An investment firm referred to in paragraph 1. 2, no. TWO, ONE. ..................... Section 2 (2) of the body of the body. 2. An investment firm referred to in paragraph 1. 2, no. TWO, FOUR. PC does not include a company, etc., if more than 15%. of the company ' s financial assets during the financial year on average, in other than securities, etc., to securities, etc., shall not be included in the shares of another company in which the first company owns at least 10%. of the share capital, unless the other company itself is an investment firm, cf. paragraph 2. If a company has a determining influence on a company, cf. Section 2 (2) of the body of the body. Two, see you there at the inventory after 3. Act. aside from these shares, and instead include the proportion of the second company ' s assets corresponding to the direct or indirect ownership of the former company in the other company.

Paragraph 4. An investment firm referred to in paragraph 1. 2 does not cover an investment centre with minimum taxation, cf. Section 16 C. A 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.

Paragraph 5. An investment firm referred to in paragraph 1. 2, no. TWO, FOUR. rectangle does not include a company, etc., which only shares the shares, drawings and shares of another company, if all shareholders of the first company in the acquisition of the shares were employed in the other company or in other companies, which : the group is connected to the other company, cf. corporation tax tenet section 31 C, unless the other or one of the other companies itself is an investment firm, cf. paragraph Second, no matter one. Act. the company may also own cash, including the placement of an appeal account, within a 15-% framework. the financial assets of the company ' s financial assets, averted on average during the financial year.

Paragraph 6. In cases covered by paragraph 1, 1 find sections 8-9, 12-14, 17 and 17 A not applicable. Paragraph 1 shall not apply in the cases referred to in section 10, section 16 (1). One, and section 18, 21 and 22.

Investment certificates in other accumulating investment associations

Companies and other people

20. In the case of the taxable subject of section 6, the benefits and losses of the transferability of transferable evidence of deposits in accumulative investment associations, cf. corporate tax havens in section 1 (1). 1, no. 5 a, in the calculation of the taxable income according to the rules set out in Chapters 1 and 2, sections 8 to 10 and 17 and Chapters 6-9.

Paragraph 2. In the case of the taxable subject of section 7, the benefits and losses of the transferability of transferable evidence of deposits to accumulating investment associations shall be included, cf. corporate tax havens in section 1 (1). 1, no. 5 a, in the calculation of the taxable income, in accordance with the rules laid down in Chapters 1 and 2, sections 12 to 14, 17 and 17 A and Chapter 6 to 9.

Investment undertakings in UCITS with minimum taxation

Companies and other things.

§ 20 A. Gains and losses on transferable evidence of deposits in UCITS with minimum taxation, cf. Section 16 C (3) of the body of the body. 1, shall be taken into account in the calculation of the taxable income according to the rules set out in Chapters 1 and 2, sections 9, 10 and 17 and Chapter 6 9, cf. however, paragraph 1 2.

Paragraph 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. 2.

Investment certificates in stock-based investment undertakings with minimum taxation

People

§ 21. Gains and losses in the case of deposits of deposits for deposits in UCITS with minimum taxation, cf. Section 16 C (3) of the body of the body. 1 that is stock-based, cf. paragraph 2 5 shall be taken into account in the calculation of the taxable income in accordance with the rules laid down in Chapters 1 and 2, sections 12 to 14, 17 and 17 A and Chapter 6 to 9.

Paragraph 2. An UCITS with a minimum rate of taxation is stock-based, if 50%. or more of the Foundation ' s stock volume in the course of the Foundation's income are on average, in transferable securities, other than those covered by Section 19 and other than shares covered by Section 22. It is also a condition that the remainder of the asset mass is placed exclusively in transferable securities, etc. and in the institution ' s administration building.

Paragraph 3. Where the applications comply with the conditions laid down in paragraph 1, the application shall be made. 2, count the assets as referred to in section 29 to 33 of the value of the subactive asset.

Paragraph 4. Where the investment institution ' s application fails to comply with the conditions laid down in paragraph 1, 2, the Foundation shall be considered to have changed the fiscal status of a debt-based investment institution with a minimum rate of taxation, cf. section 33 and corporate tax havens, section 5 F, and the rules in section 22 shall apply.

Paragraph 5. The UCITS must submit information to customs and tax administration to assess the application of the application of the application of the application for the application of the application of the application of the application Two has been complied with. The information must be submitted at the latest, at the same time as information for assessing whether the UCITS complies with the conditions for a minimum taxation unit. If the application of the application is not complied with, the UCITS must publish this.

Investment certificates in debt securities-based UCITS with minimum taxation

People

§ 22. Gains and losses in the case of deposits of deposits for deposits in UCITS with minimum taxation, cf. Section 16 C (3) of the body of the body. 1, which is bond-based, cf. paragraph Two-five shall be taken into account in the calculation of the income of the taxable income. 1. Act. However, it shall apply only if net profit or net losses of net losses are combined with net gains and net losses on debts and debts covered by the exchange rate of section 14 and 23 in excess of DKK 2 000.

Paragraph 2. An UCITS with a minimum rate of taxation is bond-based, if less than 50%. by the institution of the Foundation in the course of the institution ' s income, on average, in transferable securities, other than the shares covered by Section 19 and investment certificates, shall be covered by this provision. It is also a condition that the remainder of the asset mass is placed exclusively in transferable securities, etc. and in the institution ' s administration building.

Paragraph 3. Where the applications comply with the conditions laid down in paragraph 1, the application shall be made. 2, count the assets as referred to in section 29 to 33 of the value of the subactive asset.

Paragraph 4. Where the investment institution ' s application fails to comply with the conditions laid down in paragraph 1, 2, the Foundation shall be considered to have changed the fiscal status to a stock-based investment institution with minimum taxation, cf. section 33 and corporate tax havens, section 5 F, and the rules in section 21 shall apply.

Paragraph 5. The UCITS must submit information to customs and tax administration to assess the application of the application of the application of the application for the application of the application of the application of the application Two has been complied with. The information must be submitted at the latest, at the same time as information for assessing whether the UCITS complies with the conditions for a minimum taxation unit. If the application of the application is not complied with, the UCITS must publish this.

Paragraph 6. In cases covered by paragraph 1, 1, the rules in section 5 A, 12 to 13 A and 44 shall not apply. Paragraph 1 shall not apply in the cases referred to in section 17, 17 A and 19.

Chapter 6

Loss of profit and loss

Companies and other people

-23. The profit and loss of shares to be taken into account in the calculation of the taxable income shall be included in the income in which the profit or loss is realized (the principle of realisation).

Paragraph 2. Taxable subject to Section 7 may, for profit and loss, fall under Section 17 instead, once and for all, to add unrealized profit and loss to the stock market of the taxable income (the inventory principle). If the taxable person chooses to use the inventory, the profit or loss of income shall be, or losses, as the difference between the value of the shares at the end of the income year and the value of the shares at the beginning of the income year. In the case of shares acquired during the income year, the amount of the acquisition shall be used instead of the value of the shares at the beginning of the income year. In the case of shares held in the income of the income year, the sum of the sum shall be used instead of the value of the shares at the end of the income year.

Paragraph 3. The customs and tax administration may allow another method of handling to be used, cf. however, paragraph 1 4-8. Where such authorisation is granted, it may be amended only in accordance with the authorisation of customs and tax administration.

Paragraph 4. The taxable subject of Section 7 shall apply the storage principle for the profit and loss of investment evidence covered by Section 17 (3). Furthermore, the taxable subject of Section 7 shall apply the storage principle for profit and loss of investment proof covered by paragraph 22, if the person concerned uses the storage principle in the inventory of profit and loss of debt securities ; engaged in trade in a regulated market.

Paragraph 5. Taxable subject to Section 6 shall apply the storage principle in the inventory of the benefits and losses of shares covered by sections 9 and 17, section 20 (4). 1 and 20 A, cf. however, paragraph 1 6.

Paragraph 6. Notwithstanding paragraph 1 5, taxable subject to section 6, shall apply the principle of application in respect of the benefits and losses of shares covered by Article 9, which are not available for trade in a regulated market or in a multilateral trading facility. It is a condition that the taxable person applies the principle of realisation to all such shares. 1. Act. shall not apply where the taxable person has applied the stock price of such shares or, where the taxable person is a life-insurance undertaking. 1. Act. shall not apply to investment evidence covered by Section 20 (3). 1, or Section 20 A. 1. Act. does not apply to the drawing up of the shares, convertible bonds and the convertible bonds of convertible bonds, if the shares which can be drawn or converted will be included in trade in a regulated market or a multilateral trade area ; trading facility.

Paragraph 7. The taxable shall apply the stock price of the stock price and loss of shares, investment certificates, etc. covered by Section 19 (3). 1. In cases where the taxable and investment firm has different income, and these are shares not available for trade in a regulated market or registered in a securities market, the value at the beginning of : the investment company ' s income instead of the value at the beginning of the taxable income, and the value at the end of the income of the investment company shall replace the value at the end of the income of the taxable income. In the case of shares which the taxable person has acquired in the course of the investment company ' s income, the sum of the purchase shall replace the value of the shares at the beginning of the income year. In the case of shares held by the taxable person in the course of the investment company ' s income, the sum shall be replaced by the value of the shares at the end of the income year. In the case of the value of shares and investment certificates, etc., which are issued by an investment company, the market rate shall be the market. Where a market price cannot be determined or less than the withdrawal value, the market shall be discharged in accordance with section 19 (2). 2, no. 2, the back value of the withdrawal is used.

Paragraph 8. In the case of an investment certificate in an UCITS with a minimum rate of taxation, which has been covered by Section 16 C of the body of the body and where the investment certificate is based on the institution ' s decision on this matter or due to a lack of time, the submission of proper information on minimum income and so on shall be subject to section 19 (1). 1, the taxable income from the abstention referred to in paragraph 1 shall be discharged. 7, section 19, paragraph 1. Paragraph 1, and section 33 (4). 1, not applicable. However, this only applies if the decision takes place before the time of decision-making or before the time in which timely submission of correct information should have been carried out and the taxable not due to the outcome of a site-funden ; The general assembly had reason to assume that the decision would be taken or that timely submission of correct information would not be achieved.

§ 23 A. In the case of profit and loss at group-internal convertible bonds covered by § 9 and § 17, the storage principle is applied to the individual convertible bond. The value of the income end of the income year and the sum of the income cannot be less than the amount of the tax acquisition sum. In the group ' s internal convertible bonds, bonds are the bonds of corporate affiliates, cf. corporate tax havens, section 31 C. 1. and 2. Act. shall apply mutatis muthisis to convertible bearer bonds.

§ 24. Gains and losses are made according to the average method, cf. Section 26, cf. however, paragraph 1 2.

Paragraph 2. Gains and losses by the loss of assets and drawings of shares admitted to trading on a regulated market shall be made up of the stock for the stock method, cf. § 25.

Paragraph 3. Taxable shifting from the principle of application to the principle of stock shall use the equitable sum of the stock as the value at the beginning of the first income, where the change shall have effect. Taxable shifting from the stock principle to the principle of application shall apply the value of the stock at the end of the income year before the change of principle by the stock exchange rate at the end of the income year at the end of the income year at a later date of profit and loss on the stock. 1. and 2. Act. shall not apply in the cases covered by Section 33 A.

Paragraph 4. In the case of shares covered by Section 17, which is transferred to the taxable facility, where the taxable person has chosen to make a profit and loss in accordance with the stock principle, cf. Section 23, paragraph 1. 2, the stock shall be regarded as transferred to the plant inventory of the following revenue. In the case of a subsequent abstention, profits and losses shall be made on the basis of the value of the shares at the end of the income year prior to the changeover instead of the purchase price.

Paragraph 5. If the stock has been acquired prior to the entry of the tax obligation, the rules in section 37 on the time of purchase and the use of the purchase shall be used. In the case of termination of tax duty or tax base, the rules shall apply in section 38 in connection with the profit and loss after paragraph 1. One and two.

Assets and drawings of shares for shares admitted to trading in a regulated market

Companies and other people

§ 25. Gains and losses by the loss of assets and drawings of shares engaged in trade in a regulated market shall be dissolved as the difference between the sum and the sum of the purchase price.

Paragraph 2. The acquisition sum for assets and drawings that has been awarded to the taxable person in his capacity as shareholder of the company is 0 kr.

Paragraph 3. Paragraph 1 shall not apply in cases where gains and losses are made according to the stock principle.

The average method

Companies and other people

SECTION 26. Gains and losses by the loss of shares shall be made in accordance with the rules laid down in paragraph 1. 2-6, cf. however, section 23 (3). 2, 4, 5, 7 and 8, on the storage principle.

Paragraph 2. Gains and losses shall be calculated as the difference between the sum of the sum and the sum of the price of the stock concerned. The amount of the purchase shall mean the total acquisition sum for the stock market share of shares in the company concerned, whether or not they have different rights. A company shares a stock exchange rate under the commercial value, and the company may deduce the difference between the commercial value of the shares and the sum of the section 6 (6) of the State Treasuer (s). Paragraph 1 (a) shall be the stock in the calculation after 1. Act. shall be deemed to have been passed to the commercial value of the shares at the time of departure.

Paragraph 3. The stock options and drawing-ins for shares covered by Section 25 shall not be taken into account in accordance with paragraph 5. Paraguation 2 and 6 shall not be carried out in accordance with paragraph 1. 2 and 6 on the abstention of such corrects. The same applies to shares included in a section of section 44, and the drawing-up of the shares referred to in section 16 (3). 1 in the case of the drawing-up of shares not included in trade in a regulated market. In addition, the drawing-up of the drawing-up of the shares of the body of the body of the body of the body of the body of the body of the equation shall not include the drawing-up of the equities of shares not included in the case of inventories in accordance with paragraph 1. Two and six. Drawing courses, as mentioned in 2. and 3. Act. are not covered by the rules laid down in paragraph 1. 4.

Paragraph 4. The stock of shares not covered by Section 25 shall be regarded as shares. The carcase shall be considered to be the sum of the sum of the price of the drawing up of the design and the amount to be paid in the drawing. Drawing courses shall be deemed to have been charged as the sum of the amount of the amount of the drawing-up and the amount to be paid in the drawing-up.

Paragraph 5. Stocks in accordance with the rules laid down in section 7 A of the body of the body must first be taken into account in accordance with paragraph 1. 2 and 6 from the date on which the tape is terminated. The shares are part of their acquisition sum. In the event of an entry into the tax base, the shares referred to in 1 shall be that of 1. Act. shall, however, be taken into account under paragraph 1. 2 and 6, even if they are banded at the time of entry into force of the taxable age.

Paragraph 6. Commitment of a taxable share of shares in a company, etc., shall be allocated the total share stock of the shares in question, etc proportionally between the shares and shares of the taxable vessel. This also applies in cases where the abstention does not trigger taxation. If the shares have a value added, the distribution is made on the basis of this value. The detectable value of convertible bonds shall be shown as the due value of the stock to which the bond can be converted. The amount of the total acquisition sum, which is to be taken into account in the distribution of shares, shall be added to the profit or loss of the loss. The remainders of the total purchase price shall be deemed to be a purchase price for the shares held in the case of stocks and shall be subject to the subsequent abstentions of the shares in accordance with the preceding rules.

Avoidance of the purchase price for certain investment evidence

Companies and other people

§ 27. In cases where there is no effective payment of the minimum income from an UCITS with a minimum rate of taxation, cf. Section 16 C of the body of an UCITS, in accordance with Directive 2009 /65/EC of the European Parliament and of the Council, Annex 1 shall be deemed to be a non-effective payment as a supplement to the original proportion deemed to have been acquired at the same time as the original share and with a purchase fee corresponding to the non-payment. The non-effective payment shall be deemed to have been added to the original share at the time of the annual approval of the UCITS, but not later than six months after the expiry of the UCITS ' s revenue.

Paragraph 2. Paragraph 1 shall, however, apply only if :

1) the non-payment is not dealt with by the institute as a new deposit resulting in an increase in the nominal share of the consignon in the institution, or

2) it is not in the section 16 A (4) of the body of the body. 3, no. 1, mentioned winding-out, which is only included in the amount of the desolated amount.

Paragraph 3. If the purchase price cannot be determined, it is set to 0 kr.

Paragraph 4. Paraguation 1 to 3 shall apply mutatis mutias to the non-effective payment to taxable taxable tax on investment firms in investment undertakings with a minimum tax on a stock principle, even though the Foundation is not one ; the UCITS, in accordance with Directive 2009 /65/EC of the European Parliament and of the Council.

Reduction of the purchase of the purchase price

Companies and other people

§ 28. To the extent to which a claim or security is obtained for a claim shall be made in the case of a capital injection to the debtor or to a company and so on, in which the debtor owns more than 10%. in the case of shares of shares acquired in the capital deficit, the amount of the acquisition shall be reduced by the amount of the amount to which the proposed claim exceeds the curriment of the claim at the time of entry. Where the reduction is disclosed from the capital deficit. Reduction occurs when the capital injection is directly or indirectly carried out :

1) Of the creditor of the claim or his spouse.

2) By a company in which the creditor or creditor ' s spouse directly or indirectly owns more than 50%. of the stock or the capital chapter, or directly or indirectly, possess more than 50%. Of the voices.

3) Of a person who, alone or with his spouse, directly or indirectly owns more than 50%. of the stock or the capital chapter of the creditor or has more than 50% of the credit company. Of the voices.

4) For a company that is companies associated with the creditor company, cf. Section 4 (4) of the exchange rate law. 2.

5) By a guarantor for the claim and by persons and companies, etc., relating to the guarantor, as mentioned in paragraph 1. 1-4.

6) A former creditor or a guarantor for the claim, as well as of persons and companies, etc., which have it in paragraph 1. 1-4 related to the former creditor or guarantor. However, it is a condition that the transfer of the claim or bail must be regarded as having been done in the context of the capital deposit.

Paragraph 2. Paragraph 1 shall apply only if any loss to the proposed claim or the guarantee of the proposed claim would not be deductible from creditor or creditors for that claim. The same applies to a former creditor or a guarantor for the claim in question, when the transfer of the claim or bail must be regarded as having been made in the capital deposit. No matter what. and 2. Act. find paragraph 1. Paragraph 1 shall not apply where a loss to the shares acquired in respect of the capital deficit is not included in the inventory of the taxable income, in accordance with the provisions of the financial contribution. § 8.

§ 28 A. A claim on a capital owner for non-paid self-paid capital shall be established in accordance with the requirements of the Community. section 33 of company law shall be reduced to the amount of the purchase price of the shares drawn up in connection with the foundation of the claim, with an amount equal to the amount receivable.

Paragraph 2. The storage principle of the stock in which the purchase price is to be reduced in accordance with paragraph 1 shall be applied. 1, the value of the shares shall be reduced by the beginning of the income year of the year in which the debt is being written down. In the case of shares acquired during the income year, the amount of the acquisition shall be used instead of the value of the shares at the beginning of the income year.

§ 29. Ambient deposits which have not had to be included in the calculation of the taxable income of the part shaver, cf. paragraph 2, defray the total acquisition sum for the parties to the company. The rest of the total purchase price shall be deemed to be a purchase price for any of the parties concerned.

Paragraph 2. Ambitious amounts which have not been deduced by the deduction of the taxable income are calculated in the context of a capital reduction in an anpartcompany with a capital capital that did not overcome nominal 225,000 cranes, where : the reduction was notified to the Corporate and Corporate Management Board during the period from 1. June 1996 to and with the 30. In September 1997, and where the capital chapter of the company had been increased by cash deposits, appeals deposits or the conversion of debts from the period from and with the sixth. December 1991 to and with the 31. May 1996, or where the company had been set for this period. 1. Act. it shall cover only the part of the unloaded amount not exceeded the nominal value of the annulled parties.

Paragraph 3. Paragraph 2 shall not include the parties in the company that were acquired as part of the nutritional path of the taxable undertaking, cf. § 17, if the reduction of capital had resulted in the impact of the deposits of the deposits in the company, or if the cost of deduction was granted in whole or in part, for profit tax, in accordance with the rules of exemption for profit-making tax, liquidation provenus.

Chapter 7

Acquisitions and abstention, etc.

Acquire Time

Companies and other people

§ 29 A. Stocks acquired when converting a convertible bond is considered to be purchased at the time of conversion.

Transition, etc.

-$30. Understanding is the means of this law, trade, trade, waste and other form of a dicidation.

Paragraph 2. The concept of abstention conceals in this law the situation where profit and loss are made according to the stock principle.

§ 31. The acquisition and abstention of shares at present, inheritance or inheritance shall be placed on the market in such a way as to buy sales respectively. In such cases, the amount of the acquisition or withdrawal shall be deemed to be the amount due in the calculation of the duties, the charge or the income tax of the acquiring. If this has not been a tax or income taxable, such activity shall be regarded as the amount of purchase or withdrawal of the share of the stock concerned at the time of transfer. The rules of 1. 3. Act. shall not apply to the extent to which the transferee shall enter into the tax position of the transferor.

Paragraph 2. Replacing and insurance amounts shall be treated as a level of exhumation.

§ 32. 3) Deposits of shares and the right of drawing into shares in a savings income in retirement purposes, in a retirement party, in an old-age savings, in a retirement scheme or in a child savings scheme covered by the pension tax law, standing in the same page with abstention. The amount of bonding shall be deemed to be the value at the time when the deposit is made.

Paragraph 2. Loading of shares and drawing rights to shares from a scheme as referred to in paragraph 1 shall be : 1 is being placed on purchase. Acquisition sum is the value at the time of loading. Where the amount of the pension is paid under the pension, Section 30 B (3) is paid. However, 1 and 6 shall be used as a purchase price.

Paragraph 3. Paragraction 1 and 2 shall apply by analoging to the entry and equilisation of shares of pension schemes approved under the provisions of Article 12 (1) of the Pension Code. 1, and section 15 C.

§ 33. If an accumulative 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. Section 19, without the company and so on, changes the tax status of the company and so on shall be deemed to have been re-established and acquired again to the commercial value at the time the change takes effect from, cf. however, section 23 (3). 8. in the case of tax status, the profit and loss of the shares and shares in the company and so on in the company, etc. after the date of shift, shall be subject to rules other than the rules applicable to this ; time, cf. however, paragraph 1 3.

Paragraph 2. Paragraph 1 shall also apply where a company subject to the other tax obligations of corporation tax changes to the tax status of an investment company covered by section 3 (3). 1, no. 19.

Paragraph 3. The following tax status change does not mean that the shares of the parties, etc., shall be deemed to have been procured and reprocured :

1) If a bond-based investment institution with a minimum tax will change the fiscal status to an investment firm or an equity-based investment institution with minimum taxation.

2) If an investment company changes the fiscal status to a bond-based investment institution with minimum taxation.

Paragraph 4. The trade value of investment certificates as referred to in paragraph 1. 1 shall be deductible after deduction of loins, etc., which after the beginning of the first year of new status are rested on the income of last year, with an old status. In UCITS, with minimum taxation, as referred to in paragraph 1. 1 constitute a deduction of the load, etc., however, at least the minimum income, cf. Section 16 C of the body.

Paragraph 5. 3) In the first year of the profit or loss of the year or losses of shares issued by an investment company, section 19, cf. paragraph 2, the value of shares in the investment firm at the beginning of the year of the income year shall be reduced by the actual encoding carried out after status change, to the extent that it relates to the time before the status change. Similarly, the purchase price of shares shall be reduced when an investment firm, cf. section 19, changes the fiscal status. For the status change from UCITS with a minimum rate of taxation, cf. Section 16 C of the body of the body to an investment firm shall be reduced by the minimum of minimum income.

Paragraph 6. Stock belonging to a UCITS or an UCITS with a minimum rate of taxation which changes the fiscal status of paragraph 1. 1, so that the participants are taxed as participants in a stakeholder, are deemed to be redeemed and acquired again to the commercial value at the time when the status change has taken effect.

Paragraph 7. Taxable taxable who are taxed as participants in a stakeholder and transferred to taxation as members of a cumulative investment association, cf. corporate tax havens in section 1 (1). 1, no. 5 a, or an investment firm, cf. section 19, the transition to the trading value of the stakeholder ' s shares to the commercial value at that time is considered to be the changeover.

Paragraph 8. Taxable taxable who are taxed as participants in a stakeholder and transferred to taxation as participants in an investment institute with minimum taxation, cf. section 16 C of the body, or as members of an account-leading investment association, cf. corporate tax havens in section 1 (1). 1, no. 6, the transition is not considered to be a shareholder of the shares of the interested party.

§ 33 A. In cases where shares change fiscal status, cf. paragraph 2, the stock shall be deemed to have been procured and acquired again to the commercial value at the time of shift of fiscal status.

Paragraph 2. In the change of fiscal status, cf. paragraph 1 means the benefits and losses of the stock either :

1) switching from the scope of section 8 to be covered by sections 9, 18 and 19, section 20 (8). 1, or § 20 A, or

2) switching from the scope of sections 9, 17, 18 and 19, section 20 (8). 1, or § 20 A to be covered by § § 8 or 10.

Paragraph 3. Paraguations 1 and 2 shall apply mutatis muted to where shares in the context of a tax-free transaction are reexchanged with shares in the same or other company, when the stock has a different fiscal status other than the trading shares. Change the fiscal status of paragraph 1. 1 and 2 shall result in taxation under the general rules in sections 9, 17, 18 and 19, section 20 (4). 1, or § 20 A, irrespective of the change of status to a tax-free merger, division, the transfer of assets or exchange of shares with or without authorisation.

Paragraph 4. Paragraph 1-3 does not apply to the cases referred to in Section 33.

Family Assignment with Succession

People

§ 34. In the case of transfers in the living live of the shares, the parties may apply the rules laid down in paragraph 1. 2-4, if the following conditions are met, cf. however, paragraph 1 5 :

1) The transfer takes place to children, grandchildren, siblings, seafarers ' children, the grandchildren of the seafarers, or a coexist, meaning a person who meets the conditions laid down in the penalty slots section 22 (2). Paragraph 1 (d). The child's and adoptive relationship is treated as a natural relationship.

2) The individual transfer of shares shall be at least 1%. of the share capital of the stock or of the party capiti.

3) These are shares in a company, etc., whose activities are not largely comprised of real estate or possession of cash, transferable securities, or similar to that of the company. , cf. paragraph 6. Abduction of immovable property used for agriculture, gardenneri, nursery, orchard or forest farm, cf. section 33 (3) of the assessment. In this context, 1 or 7 shall not be deemed to be renentable.

4) The shares are not covered by section 19.

Paragraph 2. The transferee shall not be taxed by the transferor. The transferee shall be entered in the transferor ' s fiscal position by the transfer. This applies regardless of when the purchaser will be the shareholder. Upon the acquisition of the gains or losses of the acquisition by the stock, the stock shall be treated as a purchase for the acquisition sum and at the time they were purchased by the transferor.

Paragraph 3. Where the transferee is not taxable in this case, the transferee shall apply to the country according to Article 1 of the source tax base. 2, to the extent that the shares following the transfer are part of a company which is taxable for the transferee according to the section 2 (2) of the source tax. 1, no. 4. If the transferee is taxable here to the country according to the source tax code section 1, but in accordance with the provisions of a double-tax agreement with a foreign state, the Faroe Islands or Greenland must be considered to be resident there, paragraph 1 shall apply to the provisions of paragraph 1. 2 only, to the extent that the shares following the transfer are part of a company which Denmark under the double-tax agreement is subject to the right of taxation.

Paragraph 4. Source Tax Tax Section 33 C (3) 3, 4, 7, 8 and 13 shall apply mutatis muties to shares.

Paragraph 5. The terms of paragraph 1. 1, no. The provisions of 2 and 3 shall not apply to the transfer of shares as referred to in Section 17 or Section 18 (2). One or four. The conditions of paragraph 1. 1, no. 3, shall not apply in respect of the transfer of shares in a company and so on which is fuelled by the purchase and sale of transferable securities or by financing operations.

Paragraph 6. 4) The company ' s activities shall be considered to be largely in the rental of real estate or possession of cash, securities le.similar. referred to in paragraph 1. 1, no. 3, if at least 50%. income from the company ' s income, which means the net revenue for the sum of other accounts receipts, calculated as the average of the last three financial years, derived from such activity, or the commercial value of the company ' s undertaking ; rental-over, cash, transferable securities, le.e. either at the time of transfer or up to the average of the last three financial years, at least 50%. of the commercial value of the company ' s total assets. The possession of parts covered by Section 18 shall not be considered as the possession of securities. The yield and the value of shares in subsidiaries in which the company directly or indirectly owns at least 25%. of the share capital, etc., shall not be taken into account. Instead, the proportion of the subsidiary income and assets of the subsidiary shall be taken into account as the owner. In the evaluation, the income of a fixed property between the company and a subsidiary or between subsidiaries shall be disregarded. Real Estate, which is rented between the company and a subsidiary or between subsidiaries and used by the tenant in operations, is considered not to be a rental or rental service.

Assignment to cherub employees with success

People

$35. § 34, except for paragraph 1. 1, no. 1, shall apply mutatis mutilation to an employee when the employee during the last five years has been employed in a number of hours corresponding to full-time employment in composite at least three years in the company and so on which have -Issued the stock. Transfer of shares after paragraph 34, except for paragraph 1. 1, no. 1 may also occur when the employee in the last five years has been employed for a number of hours corresponding to full-time employment in a composite or several companies which are affiliated, cf. Section 4 (4) of the exchange rate law. 2, with the company that has issued the stock. By the balance of the hour after 2. Act. the number of hours in which the employee has been employed in two or several group-connected companies shall be added together. It is a condition that companies are conjoined at the same time and in the period in which the employee is after 1. Act. have been employed for a number of hours corresponding to full-time employment in composite at least three years at the company, which shall be transferred at the time of the transfer.

Paragraph 2. If the shares transferred as referred to in paragraph 1 shall be transferred. 1 has been received by the transferor as remuneration for a merger, division, assets or share exchange rates within the last five years, may be the number of hours employed by the employee in the acquiring or acquired company ; shall be taken into account in the calculation of the 10-second paragraph after paragraph 1. 1.

Paragraph 3. If the company, etc., which has issued the shares of shares referred to in paragraph 1, shall be : 1, established by the transformation of a personal owned company within the last five years, may be the number of hours employed by the employee in the calculation of the number of hours corresponding to full-time employment ; by paragraph 1.

Paragraph 4. Paragraph 1-3 shall apply mutatis muctis to the acquisition of shares of a death row by a close employee.

Assignment to previous owners with successful

§ 35 A. § 34, except for paragraph 1. 1, no. 1 shall apply by analogy to the transfer of shares to an earlier owner where the transfer to the previous owner is done within the first five years after the transferee has acquired the shares. It is a condition that the transferor acquired the shares from the previous owner and that the transferor entered the fiscal position of the former owner in the acquisition. 1. and 2. Act. shall apply by analoging to a previous owner's acquisition of shares from a death row.

Activation exchange

Companies and other people

§ 36. For the exchange of shares, shareholders in the acquiring company have access to taxation in accordance with the rules of section 9 and 11 of the Merger Tax Code, as well as the acquiring company is covered by the concept of company in a Member State in Article 3 in Article 3 ; Directive 2009 /133/EC, or are companies similar to Danish share or anpartcompanies, but which are indigenous to non-EU countries. In this context, the date of the share exchange rate shall be considered as the date of the merger. Application of the rules in 1. Act. shall be subject to authorization from customs and tax administration. The customs and tax authorities may fix special conditions for the authorisation. 1.-4. Act. shall not apply where the acquired or the transferable company in the country of taxation is considered to be a transparent entity.

Paragraph 2. In the case of the exchange of shares, cf. paragraph 1, the operation of a company acquiring a share in a company ' s share capital with the effect of obtaining a majority of the votes in this company, or, if it already has such a majority, acquires a further share of the market ; in return for securities belonging to the shareholders of the other company, to award shares or parties to the first company and, where appropriate, a cash compensatory sum. The conditions of 1. Act. whether the acquiring company shall obtain the majority of the votes in the acquired companion shall be deemed to have been fulfilled, even if the acquiring company immediately after the stock exchange is split according to the rules of section 15 a of the Merger Tax Act.

Paragraph 3. Customs and tax administration may allow tax to be untaxable in accordance with sections 9, 12 to 14, 17 to 19 and 22 in the case of a company acquiring the entire share capital of another company, or in which a company already owns shares in another company, will acquire the rest of the stock record in the other company. It is a condition that the shareholders of the other company such as remuneration alone receive shares in the first company and, if necessary, a cash compensatory sum. The section 9-11 of the Merger Tax Code shall apply mutatis mums.

Paragraph 4. It is a condition that the transactions referred to in paragraph 1 shall be made. 1 and 3 shall be carried out within a maximum period of six months from the date of the first exchange of movement. Customs and tax administration may extend the deadline in 1. Act. Replacement of shares cannot be retroactive.

Paragraph 5. Where the acquiring company is subject to section 19, paragraph 1 shall apply. 3 only if the acquiring company is also subject to section 19. If the acquired company is subject to section 22, paragraph 1 shall apply. 3 only if the acquiring company is also covered by section 22. Where the acquiring company is subject to section 21, paragraph 1 shall apply. 3 only if the acquiring company is also covered by section 21.

Paragraph 6. The exchange of shares in accordance with paragraph 1. 1-5 may be carried out without authorization from customs and tax administration. It is a condition that the value of the remuneration assets with an appendix of a possible cash compensatory sum corresponds to the trading value of the shares of the switched. It is, then, a condition that the transferable company ' s holdings shall not be devoting shares in the company acquired for a period of three years after the date of exchange. No matter three. Act. the shares of the transferable company in the period referred to in the said period shall be assisted in the case of a tax-free restructuring of the transferor or transferable undertaking of the transferee, provided that the restructuring does not take place with anything other than shares. In such cases, the condition shall be 3. Act. at the time of the remaining time, the members of the company participant or the undertakings concerned in the subsequent tax-free restructuring respectively. It is a condition for the exchange of shares without authorisation that shareholders who determine the influence of the acquired company, cf. the section 2 of the body of the body of the body of the body of a company belonging to the Faroe Islands or Greenland, a State which is a member of the EU/EEA, or a State that has a dual taxation agreement with Denmark, is retradgeted in the section 2 of the body of the same law.

Paragraph 7. At the same time, at the same time as the tax return on the income in which the share exchange relocation is carried out, the transferee shall give customs and tax administration an indication that the company has participated in an activity exchange in accordance with the rules laid down in paragraph 1. 6. If the transferable company affirm shares as referred to in paragraph 1. SIX, THREE. ..............

§ 36 A. (The case).

Chapter 8

Moto Move

Companies and other people

§ 37. Stock, which is not already covered by the Danish tax, shall be deemed to have been purchased on the actual acquisition time of the commercial value at the time of the transfer, cf. corporate tax havens, section 4 A and source tax tents section 9. When a company and so on or a person, in accordance with the provisions of a double-tax agreement concluded between Denmark and a foreign state, the Faroe Islands or Greenland, become resident in Denmark, this shall be deemed to be equivalent to the application of the rule in 1. Act. with the entry into the country of taxation in this country.

Abmove

People

§ 38. The profit and loss of shares covered by the rules laid down in this Act shall be deemed to be implemented if the profit or loss relates to a stock subject to Danish taxation, and the Danish tax-rights are terminated for the purposes other than the death of the taxable person, cf. however, paragraph 1 Two and three. However, at the time of the withdrawal of paragraph 44, the loss and loss of shares which, at the time of termination of the tax obligation, have been owned for less than 3 years, shall not be considered as a reality after 1. Act. When, in accordance with the provisions of a double-tax agreement concluded between Denmark and a foreign state, the Faroe Islands or Greenland are indigenous to the outside of Denmark, this shall be equivalent to the application of the rules laid down in 1. pkt., paragraph 2-5, and section 39-39 B, with the termination of tax duty.

Paragraph 2. The rules of paragraph 1. Paragraph 1 shall apply only to persons at the time of the termination of the tax obligation to have a stock of shares with a total value of 100 000 DKK 100. or more, unless there is a share of shares with a negative purchase of purchase.

Paragraph 3. The rules of paragraph 1. 1 shall apply only to persons who have been taxable in accordance with the same amount of the source tax, in one or more of the shares in one or more periods of not less than seven years in the past 10 years prior to the tax-duty termination. The rules of paragraph 1. However, 1 shall also apply if the shares have been obtained from the spouse of the taxable man and this satisfies the conditions laid down in 1. Act. In addition, the rules applicable to persons who are acquiring shares after sections 34, 35 and 35 A have been entered into the tax position of the transferor, and for shares acquired by a tax-free enterprise, where it was privately owned by a tax-free enterprise ; has been acquired by successful activity. The conditions of 1. Act. shall not apply to persons who have been reduced to the stock exchange value of shares referred to in section 39 A (2), as referred to in section 39 B, of the shares of the stock market which are still included. 1.

Paragraph 4. Gains and losses deemed to have been fulfilled in accordance with paragraph 1. However, in accordance with the rules of section 23-29, 46 and 47, the value shall be replaced by the end of the tax obligation instead of the sum to be discharged. In the case of shares, the taxable price may instead choose to make the taxable profit as the difference between the exploitation rate and the market rate of the stock concerned at the time of the termination of the taxman. The loss of loss may have been deducted from sections 13 to 14 and 17-19, section 20 (4). However, 2, and section 21 and 22, may only be deduced in the stock of shares deemed to have been fulfilled in accordance with paragraph 1. 1.

Paragraph 5. Tax of the total net profit shall be calculated in accordance with paragraph 1. 4 which shall be deemed to be implemented in accordance with paragraph 1. 1. The payment of the calculated tax shall be granted in accordance with section 39 and section 39 A, in the extent to which the benefits or losses of the taxable duty are to be established in accordance with the principle of application.

§ 39. Persons can obtain a payment of the calculated tax, cf. § 38, paragraph. 5, when the due is due to the termination of tax to the section 1 of the source tax, or that, in accordance with the provisions of a double-tax agreement, the person has become a non-Danish home party, cf. § 38, paragraph. ONE, THREE. Act.

Paragraph 2. Destanding by paragraph Paragraph 1 shall be subject to the fact that the tax on non-relocation etc. shall be submitted to customs and tax administration. A inventory plan must be submitted, cf. § 39 A, paragraph. 1, together with the tax return. shall be given that postponement of the tax return on the section 4 (4) of the tax control Act. 4, the submission and inventory records shall be submitted within the time limit.

Paragraph 3. The person ' s relocation etcetera shall be the subject of the person ' s relocation etc. to a country not covered by the 7 Convention. In December 1989, between the Nordic countries on aid in tax matters or Council Directive 2010 /24/EU of 16. In March 2010, the reference to paragraph shall be the following : 1 further conditional on the provision of reassuring security. The security shall be proportionate to the chaperone amount and may be placed in the form of shares, bonds covered by trade in a regulated market, bank guarantees or other reassuring security following the rule of the fiscal line. The person ' s relocation has taken place to a country which is covered by the person in 1. Act. the agreement referred to in 1. Act. whereas the said Directive and moving the person subsequently moved on to a country that is not covered by the said Agreement or Directive, shall continue to be subject to reassuring safety, as set out in the said Agreement. 2. Act. The person ' s relocation has taken place to a country that is not covered by it in 1. Act. the agreement referred to in 1. Act. the said Directive, and shall move the person subsequently on to a country covered by the said Agreement or Directive, shall be released upon request.

Paragraph 4. Entering selfcation and inventory, cf. paragraph 2, not in a timely manner, the right to hold shall be suspended and the tax shall be deemed to be due at the time the tax would be due if no reference was made. The tax is rounded by the interest after paragraph 7 (4). 2, on the levying of taxes and levies, etc., with a percentage of 0,4 percentage points per. started month from this point in time.

Paragraph 5. Customs and tax administration may disregard the deadline for the submission of tax and stock records as referred to in paragraph 1. 2, cf. paragraph 4.

§ 39 A. A stock exchange overview shall be drawn up of the shares to which the person is the owner of the time of fraction. Stock where the calculated tax, cf. § 38, paragraph. However, 5 is not to be included in the inventory summary view. In the case of a subsequent tax-free stock exchange, merger or division, the shares acquired with success shall be included in the inventory. In addition, a chaperone balance is established that is calculated by the calculated tax (the amount of the amount). The amount of the aid shall be due in accordance with the rules laid down in paragraph 1 2-10.

Paragraph 2. Where the shares included in the inventory are made, an inventory of profit or loss shall be made. No inventory shall be made in respect of the balance of shares which were covered at the time of fraction covered by Section 44. The decision is made per head. pass the stock and shall be made on the basis of the amount of the stock ' s acquisition sum and the sum of the sum. Acquisition sum included in the stock price of the stock, which was included in the calculation after paragraph 38 (3). In the case of disclaiment, they shall be deemed to have acquired shares only for the first supposed. In the payment of benefits, the rule shall be found in paragraph 1. 3 use, and in the case of losses, the rule shall be found in paragraph 1. 4 use.

Paragraph 3. Tax is calculated from the upright benefit according to the rules of Section 8 (a) of the person tax. The calculated tax shall be deductible from taxes paid to a foreign state, the Faroe Islands or Greenland, in accordance with the rules of section 33 (3) of the body of the body. 1. The calculated tax on taxes paid abroad is due to excess amount for payment. The chaperone balance shall be written down by the amount when it is paid. If the inventory is to be taken, 2 in the place would have resulted in a loss if it had been carried out on the basis of the value of the share at the time of framing and the abstention, in the case of the chaperone of the amount corresponding to the negative value of the loss as such, calculated according to the rules laid down in Section 8 of the person tax. To the extent that the person is subject to the foreign rules which they are subject to, the person shall have deduction for it after 5. Act. calculated loss is calculated a negative tax value from this. An amount corresponding to the calculated negative tax value is due for payment. However, a maximum amount shall be paid, corresponding to the negative tax value of the calculated loss calculated on the basis of the rules of Section 8 (a) of the person tax.

Paragraph 4. The one under paragraph 1. 2 livised losses shall be reduced by an amount equal to the difference between the purchase price and the value of the time of absence of a loss on the time of the flight, since the loss may not be reduced to less than : than DKK 0 The one under paragraph 1. 2 split losses shall be increased by an amount equal to the difference between the value of the asset at the time of framing and the purchase of the purchase if the time of flight was discharged on the stock concerned. On the basis of the rules of Section 8 of this category, a negative tax value shall be calculated from the loss of losses as regulated after 1. or 2. Act. The chaperone balance shall be reduced by an amount equal to the negative tax value calculated. In the case of the foreign rules covered by the subject, a loss to be made by the person in respect of the country concerned shall be calculated by a negative tax value. An amount corresponding to the calculated negative tax value is due for payment. However, a maximum amount shall be paid, corresponding to the negative tax value of the calculated loss, calculated on the basis of the rules of Section 8 (a) of the person.

Paragraph 5. In the case of shares of the issuer company, cf. Section 16 B of the body of the body and on the receipt of the profits of shares, cf. The section 16 A, which is part of the inventory ' s inventory, shall be calculated according to the rules of Section 8 of a person ' s tax. Tax deduction shall be deductible in the calculated tax on taxes paid to Denmark and deduction under the rules of section 33 (3) of the body of the body. 1, for taxes paid to foreign state, Faeroes or Greenland. Inherit the estimated tax sum of the Danish and foreign paid taxes, the excess surplus shall be payable. The chaperone balance shall be written down by the amount when it is paid. In addition, the chaperone of the chaperone with taxes paid to Denmark is being reduced.

Paragraph 6. In other outlines and dispositions made of a company in which shares in the company are included in the inventory and where the enclosure or enclosure will be able to affect the stock exchange value of the shares in downward direction, the tax will be calculated after the rules of Section 8 of the category of persons. This applies both to the outlines to the person and to other outlines and dispositions that may be assumed to be in the interest of the person concerned. Tax deduction in the calculated tax shall be deductible from Danish taxes and deductions according to the rules of section 33 (3) of the body of the body. 1, for taxes paid to foreign state, Faeroes or Greenland. Inherit the estimated tax sum of the Danish and foreign taxes decrees the excess amount for payment. The chaperone balance shall be written down by the amount when it is paid. Furthermore, the chaperone of the chaperone of paid Danish taxes is being reduced.

Paragraph 7. In the case of receipt of loans and so on from a company where shares of the company are included in the inventory statement, an amount equal to the loan payable shall be payable to the payment. The same applies if the loan is received from a company in which the company contees, as a sum corresponding to the ownership share of the aforementioned company is payable. The chaperone balance shall be written down by the amount when it is paid. The provisions of 1. 3. Act. shall apply mutatis muth to the persons referred to in section 4 (4). 2, and to companies, etc., in which the person herself or the person referred to directly or indirectly owns at least 10%. Of the capital. The provisions of 1 to 4. Act. does not, however, apply to loans to companies and so on which the borrowing company owns the entire capital. In addition, the provisions of 1 to 4 shall apply. Act. not where the forgiving company is a financial institution and the person is the owner of less than 5%. Of the stock record.

Paragraph 8. By depreciation of the chaperone of the chaperone by paragraph 1. 3-7 the balance is not writable to less than 0 kr.

Niner. 9. The person's death is equated with an abstention of all of the shares included in the inventory. The rules of paragraph 1. 2-4 and 10-12 shall apply mutatis muth.

Paragraph 10. When all of the shares included in the inventory statement have been passed, the remaining chaperone balance may be suspended. However, the chaperone balance does not lapse if the person has untapped, resulting losses, which may be produced in subsequent incomes.

Paragraph 11. The submission of taxes on each income must be submitted, where there is a positive chaperone balance. At the same time as the submission of this tax return, the address must be given of the address at the time of submission. The selvanquiary deadline is 1. July of the year after the end of the year. Expires the self-release date on a Friday or on a Saturday, and the following Sunday can be submitted on a timely manner to the following Sunday. If self-grant is not granted in good time, the distance shall be suspended and the amount on the chaperone of the chaperone shall be payable. Customs and tax administration can overlook the deadline for the submission of tax return.

Nock. 12. The time limit for payment of the amount covered by paragraph 1. 3-7, 9 and 11 are the 1. In October of the year after the year of income, the death year of the last timely payment date of the 20th year respectively. at the month of the month. If the last on-day of payment is due on a holiday or on a Saturday, the deadline shall be extended to the following daily life. If the amount is not provided in a timely manner, the sum due shall be forerunted by the interest of the interest after paragraph 7 (3). 2, on the levying of taxes and levies, etc., with a percentage of 0,4 percentage points per. started month from the due date of the month.

Paragraph 13. The customs and tax administration may request the person to submit, within a reasonable time, the documentation to be submitted for the fixing of the amount of the payment in accordance with the rules laid down in paragraph 1. 2-10. If the documentation is not submitted in good time, the reference shall be suspended and the amount that is in the chaperone of the chaperone shall be due. Customs and tax administration may disregard the time limit set by the prescribed period. The deadline for payment of the amounts covered by 2. Act. is the second month following the submission of the payment requirement with the last payment day of the 20th. at the month of the month. Nock. 12, 2. and 3. pkt; shall apply mutatis muctis.

§ 39 B. If the person is relocated in Denmark in Denmark, the rule in section 37 shall apply to shares included in the inventory inventory and that person continues to own. However, at this stage, a reduction in the commercial value of the shares held at the time of the transfer is still part of the inventory ' s inventory shall be reduced. The trade value shall be reduced by the lowest of the following amounts :

1) The remaining amount of taxation involved on the allocation of the chaperone at the time of the transfer shall be converted into the income base based on the rules of Section 8 of the person tax.

2) The total net gain of the shares owned by the person at the time of the transfer is calculated on the basis of the date of the allocation and the amount of the acquisition sum included in the calculation after paragraph 38 (5). 4.

Paragraph 2. The one in paragraph 1. 1, no. 2, the total net benefit referred to in the case of each share, which continues to be included in the inventory, shall be made of profit or loss, resulting in loss of disclosed gains. If the net decision after 1. Act. leads to a total gain of DKK 0. or a total net loss, no adjustment shall be made of the commercial value.

Paragraph 3. The amount of the trade value in accordance with paragraph 1. 1 and 2 shall be reduced by proportionate to the shares concerned on the basis of their commercial value.

Paragraph 4. Where the trade value is regulated in accordance with paragraph 1, One-three, the remaining chaperone lapses.

Paragraph 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.

§ 40. The amount of the amount according to Section 39 A is written down by the tax which the person has paid on shares included in the inventory summary as a result of company tax havens. 5, cf. Section 16 A (3) of the body of the body. 3, no. 1 (c). Saldoen is written down when the treasure is paid. The balance could not be reduced to less than 0 kr.

§ 41. (The case).

Chapter 9

Entry into force

§ 42. The Act shall enter into force on the day following the notice in Statument and shall have effect on the abstentions of the 1. January 2006 or later.

Paragraph 2. The promise of taxation of profit by the abstention of shares and so on. (Asset Taxation Act), cf. Law Order no. 835 of 29. In August 2005, shall be repealed with effect on the abstentions of the 1. January 2006 or later.

Transitional rules

Companies and other things.

§ 43. In the case of profit and loss of shares after paragraph 26, the shares acquired on the 18 shall be disregarded. November 1990 or earlier. Rule of 1. Act. , however, shall not apply if the company etcetera on the 18. November 1993, or later, new stock is heading in proportion to the trading value of shares. The rule shall also apply to 1. Act. not in the case of shares acquired from a death-estate by lodling with the success of the 18. November 1993 or later. Have the company and so on the new stock exchange rate in accordance with the heading, cf. 2. pkt., the company, etc. for shares acquired on 18. In November 1990 or earlier, the trading value of the shares is the 19th. May 1993 or the 18th. In November 1993, instead of the purchase price of the acquisition of the average purchase sum.

Paragraph 2. Loss made as a result of the fact that a company and so on in the year of income 2009 changes the status, so that it is covered by Section 19, cannot be deduced after Article 8 (3). 2, in law order no. 171 out of 6. In March 2009, even if the loss is included in this provision. The loss shall be included in the inventory in accordance with section 19 as an addition to the value of the stock or investment union in the calculation after paragraph 23 (3). 7.

Paragraph 3. Unused deductible loss as referred to in Article 8 (8) of the Asset Taxation Act. 3, cf. § 43, paragraph. Paragraph 1, section 9 A, paragraph, 3, in the order of law no. 171 out of 6. In March 2009, from the income years 2002-2009 will be deducising in net winnings in accordance with paragraph 9 (2). 1, in the year 2010, or later, cf. 2. 6. 6. Act. Loss can only be transferred to deduction in future income if it cannot be sped in net gains in a previous income. If the taxable person uses the principle of reality on portfolio tactics that are not available for trade in a regulated market or a multilateral trading facility, losses on such shares will be achieved by the 22. In April 2009 or later, only net gains are deduced from the tax burden on the market. 1. Act. does not include deductible losses on own shares, subsidiary assets, cf. § 4 A, and group corporate assets, cf. § 4 B, which will be implemented on 22. April 2009, or later. 1. Act. nor does it include deductible losses on the group internal convertible bonds and drawing corrects for this if the loss is realized on the 22nd. April 2009, or later. On the deduction of losses achieved in the year 2009, the first achieved losses shall be deemed to have been carried out first.

Paragraph 4. Tab by shift of fiscal status after section 33 A (s). 2, no. 1 to be covered by Section 9 may be dedusable in the net profits of the income year on the same shares when the shares are acquired during the period from the 23rd. April 2006 to the 22nd. April 2009. The change of fiscal status must be made at the latest on the fourth income following the income year, where the stock is acquired. The loss of a loss after 1. Act. dedude from the following revenue, in accordance with the principles applicable to losses covered by Section 9 (1). 4, as the loss alone can be deducee in net profits on the same shares. The resulting loss shall be granted in the income year in the income year and shall form part of the tax recruitment of the income concerned. The loss is lost if the shareholder after the fiscal status change draws new shares in the same company as a proportion to the commercial value of the shares. The loss shall lapses if the stock subsequently changes the fiscal status of paragraph 33 A (a). 2, no. 2, to be covered by Section 8. Life insurance companies can't discervior after 1. Act.

Transitional rules

People

Tax Exclusion for Certain Stocks

§ 44. Gains and losses in stock-listed stock, cf. § 3, nr. 1 and 2, in the Law Order No 2. 171 out of 6. This is March 2009, which has been acquired before 1. January 2006, which forms part of a stock exchange stock, cf. Section 4 (4). TWO, TWO. pkt., in law-order no. 835 of 29. This is August 2005 and per month. 31. In December 2005, an overall course shall be on or below the limit referred to in section 4 (4). TWO, THREE. pkt., in law-order no. 835 of 29. In August 2005, no account shall be taken of the income of the taxable income, cf. however, paragraph 1 3-6. In the calculation of the value of the exchange rate per year. 31. In December 2005, stocks are considered to be only on NASDAQ to be unlisted unless the taxable person chooses that the stock should be considered as being listed as children. The choice must apply to the whole of the tax burden on shares, as per one. 31. In December 2005, NASDAQ will only be converted and the customs authorities shall be notified in writing to customs and tax administration before such stock shall be refused, by the latest before the closing date for the submission of the tax return on the income of 2005. Has the taxable person for the entire period from and with the beginning of the beginning of the year to and by 31. In December 2005, together with a spouse, cf. the section 4 of the source tax shall be taken into account in the case of the stock exchange listed in the spouse, cf. Section 4 (4). TWO, TWO. pkt., in law-order no. 835 of 29. August 2005. In this case, the amount of the threshold is the limit referred to in section 4 (4). TWO, FIVE. pkt., in law-order no. 835 of 29. August 2005. In the period from the beginning of the beginning and with the beginning of the beginning of the beginning of the year and with the 31 of the beginning of income In December 2005, the period of cooperation shall be deemed to have been repealed by the end of the calendar year 2005.

Paragraph 2. The tax exemption provided for in paragraph 1. Paragraph 1 shall apply to fund assets awarded on the basis of shares referred to in paragraph 1. 1.

Paragraph 3. The tax exemption provided for in paragraph 1. Paragraph 1 shall not apply to the abstention of shares held for less than three years. Wine and loss of abstentions as referred to in 1. Act. be included in the calculation of the taxable income in accordance with the rules laid down in Chapters 1 and 2, sections 12 to 14, 23 to 25 and 28, Chapters 7 and 8, and § § 46 and 47. Loss and loss of shares included in a stock covered by this provision shall be made in accordance with the stock price for the stock method, cf. section 24 (2). Article 25 (2) and section 25 (1). 1.

Paragraph 4. The tax exemption provided for in paragraph 1. Paragraph 1 shall not apply to shares which have changed the fiscal status at the latest at the time of departure, so that they are no longer available for trade in a regulated market. In the case of profit and loss in the balance of shares as referred to in 1. Act. the stock acquired for the exchange rate shall be considered at the time of the date on which the tax status is changed.

Paragraph 5. The tax exemption provided for in paragraph 1. Paragraph 1 shall not apply to shares falling within sections 17, 19 and 22.

Paragraph 6. The tax exemption provided for in paragraph 1. Paragraph 1 shall not apply to shares which would have been covered by § 2 c or § 2 e in statutory order no. 835 of 29. In August 2005, any abstention of the 31 shall be made. December 2005.

§ 45. (The case).

§ 45 A. (The case).

Other transitional rules

§ 46. In the case of profit and loss in stock-listed shares, cf. § 3, nr. 1 and 2, in the Law Order No 2. 171 out of 6. March 2009, covered by § 12 and § 13 A, which is acquired before 1. January 2006, and as per 31. in writing.-(b) December 2005 is a part of a stock exchange stock trading stock, with an overall rate value above the limit referred to in section 4 (2). TWO, THREE. pkt., in law-order no. 835 of 29. In August 2005, persons shall be able to have the shares of the shares referred to in Article 7 (2). 1, in law order no. 835 of 29. In August 2005, a special entry value has been granted, choosing to apply this particular entry value, i.e. the equivalanal value of the shares at the time of the limit exceeding the limit, instead of the sum of the purchase price. For taxpayers with staggered income, the cure value can be per capita. 31. In December 2005, special entry value shall be used for the stock listed shares acquired by the taxable person for three years or more prior to 31. In December 2005, if the taxpayer has not been given special entry value for the stock in accordance with section 7 (2), 1, in law order no. 835 of 29. August 2005. The rules in paragraph 44, paragraph 1. ONE, FOUR, SIX. pkt; shall apply mutatis muctis. The choice must be taken together for all shares in each company. However, a deductible or a countervailable loss may not exceed the difference between the sum of the sum and the entry value of the entry value in accordance with section 7 (2). 1, in law order no. 835 of 29. August 2005 or the special assigned entry value after 2. Act.

Paragraph 2. Loss of listed stock, cf. § 3, nr. 1 and 2, in the Law Order No 2. 171 out of 6. 1 March 2009, covered by section 12, recorded in the 2002 income year or later, but before 1. In January 2006, and which could be deducieable from winnings, the 1 shall be noted. January 2006 or later in accordance with the rules laid down in section 2 (2). Article 4 (2) or Section 4 (4), 3, in the order of law no. 835 of 29. In August 2005, it may be dedufras from the rules of section 13 A.

Paragraph 3. Loss of unlisted shares covered by section 12, found in the 2002 income year or later, but before 1. In January 2006, and which could be deducieable from winnings, the 1 shall be noted. January 2006 or later in accordance with the rules laid down in section 2 (2). 2, in law order no. 835 of 29. In August 2005, yields, winnings and abstentions may be deductible according to section 16 B of the body of the body. January 2006 or later. Loss can only be deductible from yields, gains and abstentions, relating to shares where a possible benefit is covered by section 12 and in the shares relating to shares covered by Section 44. In addition, losses can be deductible only in yields, gains and abstentions, that are share income, cf. pager, section 4 a. The rules in section 13 A, paragraph 1. 2 and 3 shall apply mutatis mutis. As an unlisted stock, shares are deemed to be non-subject to section 3. 1 and 2, in the Law Order No 2. 171 out of 6. March, 2009.

Paragraph 4. In the case of profit and loss in shares covered by section 12 to 14 that are acquired before the 19. In May 1993, persons who may be abstention on the 18th. May 1993 should not have made a profit after paragraph 6 of the law order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. In December 1992, or which alone should have done so in the power of paragraph 6, paragraph 6. 6, in law order no. 865 of 22. October 1992, i.e. persons not covered by the main shareholder ' s trade value shall be the 19th value of the shares. In May 1993, instead of the purchase price, cf. however, paragraph 1 shall also One and section 44. However, this shall not apply where a possible abstention of the shares of the 18. May 1993 would have been covered by § 2 a, § 2 c or section 3 of the Law Order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. December 1992. The choice must be taken together for all shares in each company. However, a deductible or a countervailable loss may not exceed the difference between the sum of the sum and the value of the shares of the shares of the 19. May 1993.

Paragraph 5. In the case of profit and loss of employee shares from an arrangement approved in accordance with Section 7 A of the body of the body, and pursuant to this, the 19th was a tape laid down. In May 1993, persons who may be abstention on the 18th. May 1993 should not have made a profit after paragraph 6 of the law order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. In December 1992, or which alone should have done so in the power of paragraph 6, paragraph 6. 6, in law order no. 865 of 22. October 1992, i.e. persons not covered by the main shareholder ' s trade value by the use of the activity at the end of the tape in accordance with the amount of the purchase order, cf. however, paragraph 1 shall also One and section 44. However, this shall not apply where a possible abstention of the shares of the 18. May 1993 would have been covered by § 2 a, § 2 c or section 3 of the Law Order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. December 1992. However, a deduction may not exceed the difference between the amount of the sum and the value of the shares in the light of the termination of a waiver or a countervailable loss. If the person in the tape-making period has drawn new stock exchange rates in relation to the trading value of the shares, the right to apply the rule shall be lapse into the rule of 1. Act. Instead, the person may use the commercial value of the shares immediately before drawing to a head rate, cf. however, paragraph 1 shall also One and section 44.

Paragraph 6. Convert bonds acquired before 1. July 1981 and which are not covered by Section 17 shall be deemed to have been purchased for the trade value of the debt securities on 1. July 1981 instead of the actual purchase price, unless this is higher, cf. however, paragraph 1 shall also 1 and 4 and Section 44.

Paragraph 7. For persons, for whom section 6 (4). Three, last point, paragraph. 4 or 4. 7, in law order no. 865 of 22. October 1992 has had effect or would have had impact on a decision on the 18. In May 1993, the actual purchase price of the shares shall continue to be the amounts which may be established in accordance with the said provisions.

Paragraph 8. For persons who, pursuant to section 6 (2), FIVE, TWO. pkt., in law-order no. 865 of 22. October 1992 has chosen to apply an average purchase price for the shares of the person concerned on the first. In July 1981, the actual acquisition amounts shall continue to be the average purchase price sum.

Niner. 9. In the case of profit and loss on cooperatits, etc. covered by Section 18 (3). 4 that have been acquired before 19. In May 1993, persons who may be abstention on the 18th. May 1993 should not have made a profit after paragraph 6 of the law order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. In December 1992, or which alone should have done so in the power of paragraph 6, paragraph 6. 6, in law order no. 865 of 22. October 1992, i.e. persons not covered by the main shareholder ' s concept, the use of the cooperatits and other trading values of the 19. In May 1993, instead of the sum of the purchase price. The choice must be taken together for all other cooperatits and so on in each cooperative society. However, in the case of a later abstention, a deduction may not exceed the difference between the sum of the sum and the cooperatives and so of the trade value of 19 of the trade. May 1993.

Paragraph 10. The profit and loss of investment unifying evidence covered by section 22 acquired before the 19. In May 1993, persons who may be abstention on the 18th. May 1993 should not have made a profit after paragraph 6 of the law order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. In December 1992, or which alone should have done so in the power of paragraph 6, paragraph 6. 6, in law order no. 865 of 22. October 1992, i.e. persons not covered by the main shareholder ' s trade name, the commercial value of the investment unifying evidence of 19. In May 1993, instead of the purchase price, cf. however, paragraph 1 shall also This does not apply, however, where a possible abstention of the investment unifying evidence on the 18th. May 1993 would have been covered by § 2 a, § 2 c or section 3 of the Law Order no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. December 1992. The choice must be taken together for all investment unifying evidence in each investment organization. However, a deductible or unjustified loss may not exceed the difference between the amount of the sum and the trade value of investment unifying evidence on 19. May 1993.

Paragraph 11. In the case of profit or loss of investment unifying certificates, the subject of section 22 acquired before the 19. In January 1994, people may use the trading value of the investment unifying evidence on 19. In January 1994, instead of the purchase price, if the person is to be disarming the certificate of the investment union on 18. In the case of January 1994, a possible loss may not have been possible to dedushly deduciled from the loss of the taxable income, in accordance with the requirements of the payment of the taxable income. however, paragraph 1 shall also The amount of the purchase order for the profit or loss of loss of the 19 shall be used. However, no more than the trade value of the investment unifying evidence of the 19 of the UCITS may not be higher than the value of the UCITS. of January 1994 or the commercial value of the evidence at the time of departure.

Nock. 12. For persons who, in connection with the cessation of tax or relocation of the tax base before the 1 of the tax base, In January 2004, payment of the calculated tax shall be paid in accordance with the rules laid down in Section 13 a of the Law No Notice. 2 of 4. In January 2004, the requirement for collateral and calculation of addendum to the amount of the reference shall be suspended. However, the requirement for security shall be excluded only for persons who were subject to the taxable duty of a country covered by the Convention of 7. In December 1989, between the Nordic countries on aid in tax matters or Council Directive 76 /308/EEC of 15. in March 1976, as amended by Council Directive 79 /1071/EEC of 6. December 1979, Council Directive 92 /108/EEC of 14. December 1992 and Council Directive 2001 /44/EC of 15. June 2001.

Paragraph 13. In the case of persons who, according to the previous rules, apply the storage principle of profit and loss in shares as referred to in paragraph 17, this option is maintained.

Paragraph 14. In the case of shares covered by Section 3 of the Law Order No 2. 835 of 29. In August 2005, but as with effect from 1. January 2006 shall be covered by the rules in section 12 to 14 or section 20-22, persons who have applied the stock principle shall make a profit and loss account per year. 31. In December 2005, the trade value of the 31. In December 2005, instead of the commercial value at the end of the income year, In the case of shares covered by 1. Act. the commercial value of the shares shall be the 31. In December 2005, an equilibrium of profit or loss in terms of loss of the stock on 1. January 2006 or later.

Paragraph 15. Loss made as a result of the fact that a company and so on in the year of income 2009 changes the status, so that it is covered by Section 19, cannot be deduced after paragraph 14 of the Law Order No 2. 171 out of 6. In March 2009 or Clause 13 A, even if the losses are covered by one of these provisions. The losses shall be included in the inventory in accordance with section 19 as a supplement to the value of the stock or the proof of the declaration after paragraph 23 (3). 7.

Paragraph 16. Loss of listed stock, cf. § 3, nr. 1 and 2, in the Law Order No 2. 171 out of 6. This is March 2009, which has been recorded in the period from 1. January 2006 to and with the 31 st. In December 2009, however, paragraph 14 may be dedugable after Section 13 A (3). Two and three.

Paragraph 17. Section 13 (1). Paragraph 2 shall not apply where a stock has been admitted to trade in a regulated market, without complying with the condition of being listed in section 3 (2). 1 and 2, in the Law Order No 2. 171 out of 6. March 2009, and like before 1. January 2010 has been passed on not to be admitted to trading in a regulated market.

Main Action Pit

People

§ 47. In the case of profit on shares acquired prior to 19. In May 1993, the taxable person may, in the event of a possible abstention of these shares, the 18. May 1993 should have made a profit and loss after section 6 of the law no. 865 of 22. In October 1992, as amended by law no. 1030 of 19. In December 1992, a reduction in the taxable profit of the shares in question is achieved. The same shall apply to the profit or loss of assets or assets assigned to it before 1. In January 2006, on the basis of the shares in question. No reduction shall be calculated on shares falling within sections 17, 18 or 19 and shares which would have been covered by Section 2 c of the Law Order no. 835 of 29. In August 2005, any abstention of the 31 shall be made. December 2005.

Paragraph 2. Paragraph 1 shall not apply where the taxable only should have added value in the power of section 6 (4). Six, in the one in paragraph 1. 1 mentioned law-order.

Paragraph 3. Impact in accordance with paragraph 1. 1 is calculated with 1%. per Year, the taxable person has owned the shares in question prior to the expiry of the 1998 income year. The impact may not exceed 25%. Where the transferee is transferred or appointed, the transferee shall be entered into the tax position of the transferor, cf. Section 34, section 35 or death-tax bill section 36, the value of the shares shall be used for the transfer or the enclosure instead of the sum to be used in the calculation of the impact.

Paragraph 4. If the stocks are acquired at different times, the gains shall be distributed at the calculation of the time of ownership between the stock. If the shares have a value added, the distribution is made on the basis of this value. A part of the shares in the same company shall be deemed to have been first obtained by the equidae.

Faeroes and Greenland

§ 48. The law does not apply to the Faroe Islands and Greenland.

Tax Exterior, the 31st. October 2013

P.M.V.
Jens Rochner

-Lise Bo Nielsen


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,

-OH,

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.

-OH,

Official notes

1) The law provides for the implementation of parts of Council Directive 2009 /133/EC of 19. Oct 2009 on a single system of taxation on fusion, fission, partisan split, the transfer of assets and the exchange of shares relating to companies in different Member States, and in the case of relocation of a SE or SCE's registered office between : Member States, EU Official Journal 2009, nr. L 310, page 34.

2) For the taxation of portfolio tactics, cf. Article 9, which is owned by the beginning of the income year 2010, shall be used as an acquisition sum : 1) the trade value at the beginning of the year 2010, unless the party is covered by No 1. 2. If a company's total acquisition amounts on portfolio asset, cf. Article 9 (1), at the beginning of the income year 2010, exceeds the overall commercial value of those shares, this net loss may be deducted from the rules in section 9 (2). 2-5, in the net winnings of the section 9 (4) of the asset. 1, in the year 2010, or later. In the case of the inventory, the sum of the sum of shares of the shares held by the company shall be the sum of the sum of the shares of the company concerned by the company. May 2009, or later, and which had been owned for three years or more, had been owned. Net reduction shall be reduced to the extent to which the company in the income years 2007-2009 has been exempted to include the yields received by the aforementioned shares at the income statement. If, in the year 2010, the taxable income of the year 2010 will opt for portfolio management, which is not available for trade in a regulated market or a multilateral trading facility, net loss of net loss of such shares may be deducticated in the absence of rewards on the subject of a profit-based tax. The rules do not include the net cost of the stock market, where the company has been able to receive tax free returns on the basis of the section 13 (3) of the company tax-free trade. 1, no. 2, and on shares acquired in the context of a tax-free restructuring adopted on 25. May 2009, or later. Life insurance companies don't make a net loss. 2) The fiscal acquisition sum if the company had not started the 2010 revenue year of the 25. May 2009 and not owned portfolios at this time or if the company is founded on the 25th. May 2009. If the commercial value at the beginning of the income year 2010 is less than the tax acquisition sum, the acquisition shall be reduced by the received yields that the company and so on in the owner-time period has been exempted from the income of the income. The maximum reduction can be the difference between the tax acquisition sum and the trade value. Reference is made to section 22 (2). No, no, no. 525 of 12. June 2009. The value of the beginning of the income year 2010 and net losses for shares as referred to in Article 22 (3) of the Change Law. 9, shall be provided and shall constitute part of the tax recruitment for the income of the year 2010, cf. section 22 (2) of the amendment. 18.

3) Section 32 (1). 1 has effect from the year 2013 of this draft text. In the case of tax-taxed with imprest income, 2013 has the effect from and with the 2014 income year. The person concerned with imprest income from 2013 may, with effect for the income of the year 2013, make deposits as referred to in Article 16 (4) of the Pension Code. ONE, ONE. pkt., starting with 1. January 2013. For such deposits, section 32 (2) shall be : 1, effect from and with the income of the year 2013, cf. law no. 922 by 18. September 2012, section 13, paragraph 1. Two and three.

4) § 34, paragraph. SIX, ONE. pkt;, in this version, shall be the sole effect of the handover which takes place on 1. January 2012 or later. For and with the 31. In December 2014, the company ' s company may be able to do so after the choice of the taxable person, rather than being assessed according to the conditions laid down in Article 34 (4) of the Asset Taxation Act. SIX, ONE. pkt., shall be considered to be largely in the rental of real estate or possession of cash, securities le.similar. if at least 50%. income from the company ' s income, which shall mean the accounts net revenue for the sum of other accounts receipts, made up for the last financial year, or the commercial value of the company ' s rental operations, Cash, transferable securities, that's a lot of money. either at the time of transfer or at the end of the last financial year, at least 50% shall be. of the commercial value of the company ' s total assets, cf. Section 6 (2). Two, in Law No 1380 of 28. December 2011.