Law on corporate tax law

(The execution of exittax on the transfer of assets and liabilities to another EU //////////lit/passives) ;

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

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

§ 1

In the corporation tax law, cf. Law Order no. 1082 of 14. November 2012, as last amended by Section 6 of Law No 1637 of 26. December 2013, the following change is made :

1. The following section 25 is inserted :

" § 26. Companies and associations, etc., which are tax-related in a country which is a member of EU/EEA, including following a possible double-tax agreement, may choose the payment of the tax calculated by the transfer of assets and liabilities, cf. Section 5 (5). 7 and 8, and section 8 (4). FOUR, THREE. in the case of tax calculation, due to the transfer of assets and liabilities to the head office, or one of the company's and so forth, in a country that is a member of EU/EEA.

Paragraph 2. Destanding by paragraph 1 is conditional on the company or association and so on in a timely manner to customs and tax administration for the income in which the transfer has been carried out. The sellers must be reported in conjunction with the customs declaration. shall be given that postponement of the tax return on the section 4 (4) of the tax control Act. 4, the submission and notification of the choice of an execution shall be submitted within this time limit.

Paragraph 3. Customs and tax administration may disregard the deadline for the submission of taxes and communication, cf. paragraph 2.

§ 27. In the case of paragraph 26, a chaperone balance is established. The chaperone amount shall be calculated by the calculated tax on the assets and liabilities that have been transferred to the income year.

Paragraph 2. The amount of the chaperone shall be deducted, as the assets referred to as the chaperon of the chaperone (for which the chaperone is concerned) are calculated by means of an abstention, and so on, which should have been included in the inventory of the income of the taxable income, The asset continued to have been covered by the tax on taxation. Transfers that would be covered by section 26 (s). 1, if a transfer from Denmark is concerned, the assets shall not be deemed to have been passed. Deception after 1. Act. be calculated as the tax value of the calculated income calculated by the percentage referred to in Section 17 (3). One, however, it must be per day. income is at least paid a payment made up as one (1) 7 of the amount of the chaperone that provided the balance at the establishment of the chaperone of the chaperone. The chaperone balance shall be written in the payment amount when it is paid, but the balance cannot be reduced to a smaller amount than DKK 0 kr.

Paragraph 3. becomes an asset or passive subject to the subject of Section 26 of the new subject of Danish taxation, and is at this time a chaperone of the chaperone, or are all the assets and liabilities that a chaperone of the chaperone relating to, devolve, and stand then the remaining balance shall be drawn up in accordance with the rules laid down in paragraph 1. 2, as paragraph 1. 4-7 shall apply mutatis mutis.

Paragraph 4. becomes a company, etc., which has been granted for section 26, the taxable resident of a country which is not a member of the EU/EEA, including following a possible double-tax agreement, this shall be equivalent to the trade value of the assets ; and liabilities covered by paragraph 26, provided that the assets and liabilities are not or are associated with a permanent farm operating in a Member of the EU/EEA. If assets and liabilities are subject to a reference to section 26, internally transferred to a fixed operating site situated outside EU/EEA, then this shall be treated as a transfer to the commercial value at the time of transfer.

Paragraph 5. The company or the association, etc., must submit a tax return on each income, where there is a positive chaperone. At the same time as submission of this tax return, the information on the country of the assets covered by paragraph 26 shall be provided at the end of the income year. The selvanquilitic period shall be the one in the section 4 (4) of the tax control Act. 2, cf. paragraph 4, specified time limit, as referred to in section 4 (4) of the tax control. 3, shall apply mutatis mutis. 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.

Paragraph 6. The time limit for payment of the amount covered by paragraph 1. 2 and 5 are the 1. In November of the calendar year after the year of the income or on staggered income it shall be 1. November of the calendar year after the calendar year for which the advance income is replaced. Payment not later than 20. in the month in which the amount is after 1. Act. due to payment shall be deemed to be timely. If the amount is not provided in a timely manner, the amount due shall be forerunted by the interest of the paragraph 7 (7) of the levying of the charge. 2, with an appendix of 0,4 percentage points per. started month from the due date of the month.

Paragraph 7. The reference amount shall be the amount of interest at a rate of 1 percentage points above the National Bank ' s di-account, but not less than 3%. For the payment of interest rates, the 1 shall be the free charge. In November of the calendar year after the year of the income or on staggered income it shall be 1. November of the calendar year after the calendar year for which the advance income is replaced. Payment not later than 20. in the month in which the amount is after 1. Act. due to payment shall be deemed to be timely. If the amount is not provided in a timely manner, the amount due shall be forerunted by the interest of the paragraph 7 (7) of the levying of the charge. 2, with an appendix of 0,4 percentage points per. started month from the due date of the month. "

§ 2

Paragraph 1. The law shall enter into force on 1. March, 2014, and have effect from the year 2013.

Paragraph 2. Companies and associations, etc., which at the time of transfer were tax-related in a country which is a member of the EU/EEA, and which have obtained tax on assets and liabilities according to the rules of section 5 (5) of the company tax. 7 or 8, or 8 (8). FOUR, THREE. pkt; by means of a transfer in the income year 2008, 2009, 2010, 2011 or 2012 of the assets or liabilities of the main office or one of the firm operating sites of a company belonging to the EU/EEA, can choose the following rules : in the section 26 and 27 of the company tax bill, section 26 and 27 of this law. 1. However, the object may only be obtained to the extent that the company and so on continues to own the assets or liabilities that triggered the payment of the tax payment, and the extent to which the assets or liabilities concerned may not be deemed to be deemed to have been passed, if so, if : the rules of section 27 (s) of corporation tax. 4, as drawn up by the paragraph 1 of this law. 1, had been in effect. Distance after 1. Act. shall include the calculated tax on the transfer reduced by the payments which should have been paid in accordance with the rules of section 27 of the company tax bill in section 1 of this Act. 1 if the company, etc., had been covered by the rules of section 26 and 27 of the company tax bill, as provided for in Article 1 (1) of this Act. 1, already at the time of transfer. The subject is subject to the undertaking by the company and so on to make up the payments which were to have been paid for the section 27 of the company tax bill in section 1 of this law. 1 if the company, etc., had already been covered by the transfer of the transfer. The decision and notification of the choice of execution shall be submitted to customs and tax administration by 30. June 2014. In the case of the choice of the henchman, the part of the necessary paid tax shall be repaid, where appropriate, the difference between the paid tax and the chaperone of the chaperone who has been discharged after 3. PC, since the refund shall be made no later than 1. November 2014. An interest shall be added to the interest rate corresponding to the interest rate in paragraph 7 (7) of the levying of the interest of the interest. 2, with an appendix of 0,4 percentage points per. started month from 1. November 2014, if the repayment occurs after this date.