Section I	Taxable
TITLE II	Entrement of income tax (income)
TITLE III	The taxable income
TITLE IV	Calculation of income tax
Section V	Determination of lesions and collection
TITLE VI	Other provisions
TITLE VII	Entry into force and transitional provisions

Publication of the law on income taxation of limited liability companies and so on (Corporate Tax Code) 1)

In this way, the income tax of limited liability companies is announced and so on. (The Corporate Tax Code), cf. Law Order no. 1082 of 14. November 2012, with the changes that are being made by Section 2 of Law No 513 of the seventh. June 2006, section 1, no. One, two, and four-seven, in the law. 1381 of 28. December 2011, section 10 of law no. 433 of 16. May 2012, section 2 of the law. 923 by 18. September 2012, section 2 of Law No 1254 of 18. December 2012, Section 17 of Law. 1354 of 21. December 2012, Section 1 in Law. 1394 of 23. December 2012, Section 17 of Law. 600 of 12. June 2013, section 1 of law no. 792 of 28. June 2013, section 2 of Law No 1347 of 3. December 2013, section 2 of Law No 1562 of 20. December, 2013, section 6 of the law. 1637 of 26. December, 2013, Law No. No. 170 of 26. February 2014, section 2 of Law No 274 of 26, March 2014, section 2 of Law No 528 of 28. May 2014, section 6 of the law. 1286 of 9. December, 2014, Section 5, Act 5. 1374 of 16. December, 2014, and section 4 of the law. 1375 of 16. December 2014.

The changes resulting from paragraph 4 of Law No 624 of 14. June 2011 is not the work of this notice, as the change subsequently has been cancelled, cf. Section 6 of law no. 1255 of 18. December 2012.

Section I

Taxable

§ 1. Taxable under this law shall be borne by the following parties and associations, etc., which are established in this country :

1) registered limited liability companies and analogues ;

2) other undertakings in which none of the participants shall be personally liable for the undertaking ' s obligations and which distributes the profits from the parties in the company deposited capital, companies covered by sections 2 C and registered companies with limited liability ;

2a) austerity crates, donations and associations established in accordance with Section 207 of the financial undertaking ;

2b) registered employee investment firms in accordance with Section 7 of the Employee Investment Companies Act,

2c) (Aphat)

2d) DSB,

2e) Electrical companies, in whose activities they include the production, transport, trade or the supply of electricity. The tax obligation shall apply regardless of the type of organization of the electrical company. However, registered limited liability companies shall be subject to no. 1. if any activity as mentioned in 1. Act. exercised by a stakeholder, the stakeholders shall be taxed by the stakeholders in accordance with the rules laid down in this provision, cf. however, section 3 (3). 7. Production and consumption of electricity in trains, ships, aircraft or other means of transport and the production of electricity on emergency power plants in cases where the normal electricity supply fails to do so does not result in a tax obligation after this ; provision, if the company does not, incidentally, have activities as referred to in 1. pkt.,

2f) municipalities running the network and other activities which are either covered by Section 2 (2) of the power supply. 1, or exempt from paragraph 2 (2). 4, from the provisions of the electricity supply law (power business), cf. however, section 1 (1). 1, no. 1 and 2 e. This tax shall include revenue of such activities as well as profit and loss in the case of dispose, abstention or abandonment of assets that have or have been associated with such activity. If the municipality produces electricity and heating in cogeneration, the taxable shall also include income from heat production. However, the income of the production of electricity and heat from the burning of waste shall be exempt from the taxable duty,

2g) Energinet.dk,

2h) water-supply companies covered by Article 2 (2) ; 1, in the case of the organisation and economic situation of the water sector and waste water services, which, in this law, are interpreted as entities, etc., which, for others and on payment processes, treat or transports waste water. Tax obligations shall apply irrespective of the water-the organisation ' s organisation ' s organisation ' s organisation. However, registered limited liability companies shall be subject to no. 1. if any activity as mentioned in 1. Act. are carried out by a stakeholder, a limited-in-command company or a limited-in-command company, and shall be taxed by stakeholders, the complementarity and in the case of the bodists, in accordance with the rules laid down in this provision,

2i) Naviair,

(2j) Danpilot,

3) cooperatives, in this law, associations, the purpose of which is to promote at least ten members ' common business interests through their participation in the organization's activities such as buyers, suppliers or otherwise, if : non-members are not significantly or prolonged exceeding 25% in the longer term. by the total turnover and which, apart from the normal interest rate of a paid member, is using the site-found turnover with the members as the basis for the encoding of these. Parensorority associations may be subject to 1. PC, even if they own shares or parties in companies which do not meet the conditions of 1. pkt.,

3a) non-subject to non-subject (s). 3 for the purpose of promoting the common interest of Members through their participation in the activities of the association or in the whole or in part of the association of undertakings, provided that deliveries are used wholly or partly to the members of their members ; private consumption of the members of the Member States, and where the charges, other than the normal instalment of a paid member, to members, if any, where the provision of this association applies only to personal members, takes place on the basis of the association ' s or other members ; and the turnover of the underlying undertakings with the members of the members concerned or the association of the unification of the use of the trade union movement or the promotion of general consumer interests by the consent of the Treasure of the Trade Union shall be chosen instead.

4) associations, the purpose of which is to promote the common interests of the members of the Member States through their participation in the activities of the association, such as the takers, suppliers or otherwise, and which are not covered by No 2. 2, 3 or 3 (a),

5) reciprocal insurance associations not covered by Section 294-303 of the Act of Finance, unless the reciprocal insurance association operates exclusively from the health insurance undertaking and the customs and tax administration that it has been determined that it is not : the insurance association concerned shall be subject to no. 6, as well as companies, associations, etc., which have occurred when a mutual insurance association has been changed after the transfer of its insurance undertaking, as set out in the case of the insurance undertaking. section 14 of the bird tax law and which are not covered by No 1. 1, no. 2 or the Fund-Taxation Act,

5a) investment associations that issue the transferable evidence of the members ' deposits, except for investment firms, cf. Article 19 (1) of the asset on the part of the asset. 2, except for investment undertakings with minimum taxation, cf. Section 16 C of the body of the law, which is investment associations,

5b) funds and associations, as mentioned in section 214-216, in the Act of Financial Company, Municipality Credit and Danish Export Fund Fund,

5C) UCITS with minimum taxation, cf. Section 16 C of the body of the body, where the taxis alone shall include income in business and profit or loss in the case of dispositions, abstention, or abandonment of assets that have or have been associated with the business enterprise.

6) other associations, corporations, foundations, grants and self-weighting institutions, cf. however, section 3, in so far as the association and so on is not covered by the Fund Taxation Act. Taxation shall include the income of commercial activities and profits or losses in the case of dispositions, abandonment or dissent of assets that have or have been associated with the business enterprise.

Paragraph 2. In the statement of the Member State of the Member States, for the Member States in question. 1, no. 3, the cooperatives referred to shall be regarded as a single member. The decision as to whether or not the companies are involved is in accordance with the provisions of section 4 (4) of the exchange rate of the exchange rate. If one of the members of a co-union is governed by paragraph 1, it shall be subject to the provisions of paragraph 2. 1, no. 3, the members of this association shall be included in the statement of the Member State.

Paragraph 3. The one in paragraph 1. 1, no. 3, mentioned restriction, after which the turnover of non-members shall be 25%. in the case of total turnover, the turnover shall be deemed to be significantly exceeded if the turnover of non-members in an income exceeds 35%. of the total turnover. The transcription is considered to be of longer duration if the turnover of non-members of each successive income has exceeded 25% of each other. Provided that the turnover of non-members is new to be less than 25%. for the total turnover, the association shall be covered first by paragraph 1. 1, no. 3, where this has been the case in each 3 per successive income. For the purposes of the statement of the turnover of members and non-members, the composition of the turnover carried out by the balance of the taxable income shall be used in accordance with the conditions laid down in the report. ~ § 15-16 A.

Paragraph 4. As an income in commercial activities for the purposes of paragraph 1, 1, no. Point 5 (c), or No, 6, UCITS, etc. shall be considered to be income by means of a business or other business activity, including the maintenance of operations, renting or renting a firm of real estate. In cases where an association of other countries has a right to share in the profit of an enterprise which is not operated by the association in question, it shall also be considered as a commercial income for the association of the association and the other ; However, this does not apply to aid and support funds for the employees or former employees or workers or their relatives.

Paragraph 5. Overshot, as in paragraph 1. 1, no. Point 5 (c), or No, 6, mentioned associations, etc., in the case of deliveries to members, shall not be considered as gained in the business of professional activities.

Paragraph 6. Companies and associations, etc. covered by paragraph 1. 1, no. 2-6, shall be regarded as indigenous in this country, if the company or association etcetera is registered in this country or has the seat of the management here in the country. The provision in 1. Act. does not, however, apply to a corporation or association, etc., which are subject to full tax duty in a foreign state according to the tax rules of this State, the Danish double-tax agreement of the State in question means that Denmark shall be lewd. the double taxation of income from a firm operating facility in the State concerned by reducing the Danish tax of this income with a greater amount than the amount paid in the tax of that income in the State concerned.

Paragraph 7. An evissoring unit for investment is covered by Section 16 C or an account-leading investment association only covered by paragraph 1. 1, no. Point 5 (c), or No, 6 if it has at least 8 members unless an effective marketing is made to the public or to the greater part of it, in order to bring the number of members up. Corporate members, cf. Section 4 of the exchange rate law shall be taken into account in this context for one member.

Paragraph 8. A supporting investment association shall be subject to the section 16 C of the body of the body or an account-leading UCITS with less than 8 members who do not satisfy the requirements of paragraph 1. However, paragraph 7 shall be subject to paragraph 1 1, no. Point 5 (c), or No, 6 if any investment evidence in accordance with a statutory requirement to this effect is given by name, and where, in accordance with the requirements of a statutory requirement, members are members of legal persons and where no participants are entitled ; in the legal persons, the direct income of the investment certificate or of the income from the UCITS according to the rules of natural persons shall be taxed. Exasting UCITS with a minimum level of taxation covered by Section 16 C of the body of the body must not be able to be recorded as members.

§ 2. The tax obligation under this law shall also be borne by companies and associations, etc., as mentioned in section 1 (1). 1 having head office abroad in so far as they are :

a) carries out an occupation with a firm operating position in this country, cf. however, paragraph 1 6. Exercise of the professions on board a ship established in this country shall be regarded as the exercise of permanent farm operations in this country where the exercise of the profession in question would be considered to be carried out by a permanent occupation, operating facility here in the country. The tax obligation includes the exercise of permanent farm operations here in the country or the participation of a business establishment with a firm operating premises. This tax shall also include income in the form of continuous benefits arising from such a company, or from the abstention of such a company, when the benefits are not dividenties; interest or royalties shall be paid. The tax requirement also includes the suspension of such a company. The construction or installation work shall be deemed to be a permanent operating place from the first day. The tax shall also include profit or loss in Disposal, abstention or abandonment of property associated with such a company. In the case of shares, the tax requirement for fixed operating establishments with the exception of companies covered by Section 2 A (3). 1, profit, loss and return on company ' s shares when the return relates to the fixed operating location, including the benefits, losses and profits of shares forming part of the fixed plant capital and the re-taxing balance after section 31 A.

b) in the property of owner, medejer, brugs or revenue, the earnings of an income of one in this country shall be the property of the country of residence. In addition, tax shall include profit in the affixed of immovable property covered by the property tax law or the section 21 of the depreciation of the depreciation Act,

c) the yield shall be placed under the section 16 A (1) of the body of the body. 1 and 2, excluding the yield from UCITS with a minimum taxation covered by Section 16 C, which only invests in claims covered by the exchange rate law, shares in the management company that is required ; the administration of the UCITS, financial instruments of the Financial Instruments of the Financial Authority, and shall be provided for in UCITS, with minimum taxation, covered by Section 16 C, which only invests in assets as mentioned in : this provision, or the harlot of steel, is covered by Section 16 B (4) of the body of the body. 1. As a result, grants will also be treated for companies connected, cf. Section 31, if the grant recipient, where this was parent company to the subsidy-sylar, would be taxable of the yield after this provision. The tax obligation does not include the yield of subsidiary assets, cf. Whereas Article 4 A of the asset is subject to the tax on providers of subsidiaries to 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 Faeroe Islands, Greenland or the State where the parent company is native. Moreover, the tax obligation does not include the benefits of corporate assets, cf. Article 4 B, which is not a subsidiary asset, where the provider of companies is resident in a Member State of EU/EEA, and the tax on profit should have been dropped or reduced in accordance with the provisions of the Directive ; The European Union or double taxation agreement with the State in question, if it had been a subsidiary activist, has been the subject of a double tax agreement. Furthermore, the taxman shall not include the proceeds made by participants in parent undertakings included in the list of companies referred to in Article 2 (a (i) of Directive 2011 /96/EU on a common taxation system for mother-and subsidiaries from different Member States, but which, in the case of taxation here in the country, are considered to be transparent units. It is a condition that the company delta is not indigenous to this country. 3. and 4. Act. shall not apply where the yield from the Danish company is a further dislocation of yield received by this company directly or indirectly by subsidiary assets or group holdings, cf. the section 4 A and 4 B of the asset ' s holdings in a company belonging abroad and the Danish company was not a legal owner of the yield received. However, this does not apply where the taxation of the profit from the Danish company is to be waived in accordance with the provisions of Directive 2011 /96/EU.

d) interest shall be collected from sources here in the country of debt, such as a company or association, etc. covered by section 1 or a has to legal persons, as mentioned in section 3 B (controlled debt). However, this does not apply to interest on claims linked to a fixed operating point covered by point (a). Taxation shall not include interest if the tax on interest is to be dropped or reduced in accordance with Directive 2003 /49/EC on a common system for the taxation of interest and royalties paid between associated companies in different Member States ; or after a double-tax agreement with the Faeroe Islands, Greenland or State, where the receiving company and so on is a resident. However, this only applies if the paying company and the receiving company are associated as mentioned in this Directive in a consecutive period of at least 1 year within which the time of payment is to be located. Taxation shall be suspended if a Danish parent company and so directly or indirectly have a determining influence in the receiving company, etc., cf. Section 31 C, for a continuous period of at least 1 year, within which the time of payment is to be. In addition, the tax obligation shall lapd if the receiving company and so on is under the influence of a parent company, etc., that are indigenous to the Faroe Islands, in Greenland or a State which has a double taxation agreement with Denmark, if so, company, etc., in accordance with the rules on the Faroes, in Greenland or this State may be subject to CFC taxation on interest rates, provided that the conditions under these rules have been met. Moreover, the certificate of tax shall also lapses if the receiving company and so on proves that the foreign corporation tax on interest rates constitutes a minimum of the Danish corporation tax rate and that it does not pay interest rates to another foreign company ; etc., which have been subject to company taxation of interest rates less than the Danish corporate tax rate,

(e) the country of income obtained from that country, which, in accordance with the provisions of the source of the source of Article 43 (3), shall be provided. point 2 (h) should be taken into account A-income if it is paid out to a person ;

(f) an income as a consultant, consulting or other similar co-aid for a company in this country. However, it is a condition that a person who is or has been taxable from the source of the source tax on Article 1 (s) shall be no. 1, directly or indirectly, in the management of, control of or capital of the foreign company or association and so on and have, or at any time, within the preceding five years prior to the termination of the full tax duty have had, directly or indirectly part of the management, control of, or capital of the undertaking in this country, which shall be the remuneration. The decision shall be drawn up when it is a company and so on, whether or not the person owns or has owned 25%. or more of the share capital or advises or has the Council more than 50%. of the voting value in the company. The provisions of Article 4 (4) of the Asset Taxation Code. 2 shall apply mutatis mutis. If the paying company is personally owned, see whether the person in question owns or has owned 25%. or more of the own funds or have or have had a decisive influence in the company. The applicable criteria for shareholders shall apply mutatis mut;

g) uppeat royalty from sources here in the country, cf. the section 65 C (6) of the source tax. However, this does not apply to royalty of an exclusive linked to a fixed operating point covered by point (a). The tax obligation shall not cover royalty covered by Directive 2003 /49/EC on a common system for the taxation of interest and royalties paid between associated companies in different Member States. However, this only applies if the paying company and the receiving company are associated as mentioned in this Directive in a consecutive period of at least 1 year in which the time of payment is to be located ;

(h) in the country of claims made on such conditions, the exchange of couriers from sources in this country shall be paid to a pre-established exchange rate in relation to the value at the time of the establishment, if the debtor is a company or association etc. in section 1 or (a) and creditor, the debtor is associated with the debtor, as referred to in section 3 B (controlled debt). The taxable exchange rate shall be made up as the difference between the value of the claim at the time of the Foundation and the agreed inexcusable sum. If the wrapping is made through payments, a large proportion of which corresponds to the ratio between the sum of the deposit of the purchase of the purchase of the purchase of the purchase of the deposits and on the other side of the sum of deposits. The provisions set out in point (d shall apply by analogy to the exchange rates.

Paragraph 2. Income in a firm operating facility in this country as the income that the operating facility may have obtained, including its internal transactions with other parts of the undertaking which the operating place is a part of, if it had been a separate and independently, undertaking engaged in the same or similar activity under the same or similar conditions, taking into account the operations carried out, the assets being used and the risks to be taken by the undertaking in question ; the operating facility. Where a double tax agreement has been concluded with the foreign state, the Faroe Islands or Greenland, where the undertaking is established and the Article on the profit of the business organization is not formulated in : compliance with 1. on point, however, the income in the operating facility is discharged in accordance with the provisions of the relevant Article.

Paragraph 3. The tax obligation pursuant to paragraph 1. 1 (b) and (f) alone shall comprise only revenue from those sources of income. The income tax pursuant to paragraph 1. 1 (c) shall be 27%. of the total yields or abstentions. However, the income tax is 15%. in the case of yields or abstentions, if the competent authority of the State, in Greenland or in the Faroe Islands, where the company and others are indigenous, must exchange information with the Danish authorities following a double-tax agreement, another the international agreement or convention or an administrative agreement on aid in matters of taxation. The taxable shall be definitively satisfied by the retention of yield tax or tax to be paid under the source of the source tax of Article 65 A (3) (a). 1. This is a condition of the use of 3. pkt. that the company and so on owns less than 10%. of the share capital of the profit-giving company. Moreover, if the company and other countries are resident in a country outside the EU, it is also a condition that, together with the parties involved, see it in accordance with the group. The section 2 of the body of the body is less than 10%. of the share capital of the profit-giving company. 2.-6. Act. also includes companies belonging to a foreign state, in Greenland or in the Faroe Islands, following a double-tax agreement. The income tax pursuant to paragraph 1. 1 (d) and (h) shall be 25%. of the interest and abstention. The taxable shall be definitively satisfied by the tax rate referred to in the source tax of Article 65 of the tax on interest. The tax obligation pursuant to paragraph 1. Paragraph 1 (e) shall be definitively met by the tax paid under the source of the source tax of the source tax of the source of the income tax in accordance with paragraph 1. 1 (g) shall be 25%. of the royalty amount. The taxable shall be definitively fulfilled by the holding of the source of royalty tax by the source tax of the source tax.

Paragraph 4. The representative of the representatives referred to in paragraph 1 shall be subject to : Paragraph 1 shall be responsible for the establishment of a limited tax-ductious undertakings and associations and so on.

Paragraph 5. The provisions of paragraph 1. 1-4 shall apply mutatis mutable to undertakings and associations, etc., where they are located in Greenland or the Faroe Islands.

Paragraph 6. Sales company only in the form of distance selling through a representative with a power of attorney to bind the proxy giver but which is not an employee of the recipient of the holder shall not result in a fixed operation for the full power giver. For distance contracts, the order of the representative from Danish or foreign customers via telephone, telex, fax, mail, EDI (Electronic Data Interchange) shall be the subject of the order of the Danish or foreign customers. Equine. It is a condition that neither the power holder or any of the group-related company, etc., cf. Section 4 (4) of the exchange rate law. 2, or a person or a close-holder who verifiers the power of attorney or a group-related company, cf. Section 16 H (3) of the body of the body. SIX, THREE. or a fund or trust set by one of these companies, persons or persons in Denmark who are engaged in business operations, which are in the context of the sale of the representative.

Paragraph 7. Paragraph 1-4 shall not apply to companies, as referred to in section 2 C, which is registered abroad, in Greenland or in the Faroe Islands.

§ 2 A. If a company or association, etc. as referred to in paragraph 1 in accordance with the rules of a foreign state, on the Faroe Islands or in Greenland, is treated as a transparent unit, resulting in the income of the company and so on by the specification of the conglomers. the taxable income of legal persons in this foreign state, on the Faroe Islands or Greenland, the company and so on shall be deemed to be transparent.

Paragraph 2. Paragraph 1 shall apply mutatis mutinis if a corporation or association, etc. as referred to in Article 2, in accordance with the rules of a foreign state, the Faroe Islands or Greenland is treated as a transparent unit, thereby including the income of the company and so on. the uptake of the taxable income of the group-connected entities in this foreign state, the Faroe Islands or Greenland.

Paragraph 3. A foreign company which, in accordance with the rules of a foreign state, on the Faroe Islands or Greenland, is considered to be a transparent entity of other foreign legal persons who, in accordance with the rules of the State concerned, have to include income from companies in accordance with the rules of the State concerned ; in section 1 and 2, sections 1 and 2 are considered to be subject to transparency. However, a foreign company shall not be considered to be a transparent entity if it is taxed as a tax-resident in another foreign state, which is different from that of the State concerned in 1. and, if this other foreign state is the Faroe Islands, Greenland, a Member of the European Union or the EEA, or a State that has a double tax agreement with Denmark. Interest and royalty payments to the foreign company of two. Act. be deductible only if the source of taxation is to be dropped or reduced in relation to the foreign company, after Directive 2003 /49/EC, on a common system for the taxation of interest and royalties paid between associated companies in Member States, or after the double-tax agreement with the Faroe Islands, Greenland or the State where the foreign company is indigenous. A foreign company is understood to mean a company that is not covered by sections 1 and 2.

Paragraph 4. Paragu.1-3 shall apply only if the group-related legal persons control the company and so on, cf. Tax Control Law, section 3 B, and the foreign state, the Faroe Islands or Greenland is a member of the EU or the EEA, or has a double taxation agreement with Denmark.

Paragraph 5. The fact that a company is subject to paragraph 1. 1 or 2 does not, in itself, mean that its assets or liabilities shall be deemed to have been deemed to have been acquired. Assets and liabilities, which are intact in the event of a company which is reeligible under paragraph 1. 1 and 2 shall be treated in the calculation of the taxable income for the transparent unit, as if they were acquired at the time of their acquisition by the eligible company, and for the acquisition of acquisition sums, to which they are acquired ; Company. Any tax depreciation and depreciation that the qualified company has carried out shall be deemed to have been carried out by the transparency unit. The section 8 (5) of the Merger Tax Code. 2 4 shall apply mutatis muted to the requalifying process. No acquisition sum shall be fixed on goodwill or any other immaterial assets referred to in Section 40 of the depreciation Act, to the extent that they are the work of the eligible company itself : the transparent unit succedes to the right of manufacture ; deficits, cf. § 12, and untapped deductible losses from previous income, cf. Article 9 (4) of the stock-tax system. 4, and section 43 (3). 3, the Danish exchange rate law, section 31 (1), 3, and section 31 A (1). 3, and the property section 6 (6) of the property. 3.

Paragraph 6. If a company ceasesparates to be transparent in accordance with paragraph 1, 1 or 2, the company ' s assets and liabilities shall be deemed to have been derived from the company ' s owners to the commercial value. The company shall then be deemed to have acquired the assets and liabilities of companies connected. Section 8 B shall apply mutatis muth. The pre-payment deficit and untapped deductible losses in the company shall be suspended.

Paragraph 7. If a company ceasesparates to be transparent in accordance with paragraph 1, 1 or 2, the owners of the company shall be regarded as having acquired the shares in the company at the time of the commercial value at the time of the transparency of the trade.

Paragraph 8. The individual owners of the items referred to in paragraph 1. One of these companies is always considered to have a firm operating facility in Denmark. All assets and liabilities owned by the items listed in paragraph 1. 1 companies shall always be considered to be assigned to the fixed operating premises of their owners.

Niner. 9. If two or more Danish companies are considered to be transparent units of the same foreign company, the Danish companies shall show solidarity for the total tax payment.

Paragraph 10. Paragraph 1-3 shall not apply to foreign companies which are covered by Section 31 A.

§ 2 B. If a company or association, etc., as mentioned in section 1, has a debt of le.equal. the debt and so on shall also be regarded as own funds in the Danish income statement for a person or company which is resident abroad and the claim and so on by foreign tax rules shall be deemed to have been deposits. 1. Act. shall apply only if the foreign person or the foreign company has a determining influence over the company, or if companies are affiliated, cf. The Section 2 of the equation.

Paragraph 2. Qualification pursuant to paragraph 1. 1 means the company's interest payments and the exchange rate shall be deemed to be profit-making charges.

Paragraph 3. Paraganes 1 and 2 shall apply by analogs to companies covered by Section 2 (1) and (2). 1 (a) and (b).

Paragraph 4. Paraguation 1 to 3 shall apply mutatis muted, even though, according to the extent of foreign tax rules, the creditor of the creditor himself has a debt to a group-related company, for which there is a deposit in capital. 1. Act. shall apply mutatis muted, even though there may be several creditor links. 1. Act. shall not apply where source taxation is to be waived or reduced in relation to the creditor in accordance with Directive 2003 /49/EC on a common system for the taxation of interest and royalties paid between associated companies in different Member States ; or after a double taxation agreement with the Faeroe Islands, Greenland or the State in which the foreign creditor is indigenous.

§ 2 C. Taxable branches of foreign and tax-based entities, registered in the country of registered registration or in the seat of the seat in this country, are taxed in accordance with the rules for companies covered by Section 1, paragraph 1, no. 2 if direct owners with more than 50% are in the case. of the capital or possession of more than 50%. of the voting rights in one or more foreign states, on the Faroes or Greenland Islands,

1) where the branch, respectively, is treated as a tax subject to the branch as an independent tax subject, or

2) which does not have a double taxation agreement with Denmark, after which the source tax on providers for companies should be waived or reduced and is not a member of the European Union.

Paragraph 2. Interest and royalty payments to owners shall be deemed to be internal payments that may not be dedured if the payment by the rules of the owner's home country is considered to be an internal payment. 1. Act. the corresponding use shall apply to exchange gains on claims which have been established on such terms that the debt must be paid to a pre-established exchange rate in relation to the value at the time of the establishment. The source tax after Article 2 (2) is taxed. 1 (d) (g) and (h) shall be waived if there are no deductions after 1. or 2. Act.

Paragraph 3. In the case of tax transparency, legal persons who, in accordance with Danish tax rules, do not constitute an independent tax subject, but whose circumstances are regulated by company law, a corporate agreement or a association statute.

Paragraph 4. The participants shall not be regarded as having passed the assets and liabilities of the transparency unit or branch at the time of the qualification following paragraph 1. 1. Assets and liabilities which are no longer covered by Danish taxation shall be deemed to have been treated by the participants in the commercial value at the time of eligibility for the qualification referred to in paragraph 1. 1.

Paragraph 5. Assets and liabilities shall be treated in the calculation of the taxable income for the company as if they were acquired at the time of the participants, and for the amounts of acquisition, to which they are acquired by the participants. No acquisition sum shall be fixed on goodwill or any other immaterial rights as referred to in Section 40 of the depreciation Act, to the extent that they are worked out by one or more participants. The only thing in relation to the purchase price can be counted at a maximum of a sum equal to the difference between the sales sum and the commercial value at the time of withdrawal under Danish taxation. Any tax depreciation and depreciation taken by the participants shall be regarded as having been carried out by the company. § 4 A, paragraph 1 The corresponding use of depreciation eligible assets shall apply to the extent that they are not already covered by the Danish tax rate, since they shall be deemed to have been acquired at the time when the individual participants acquired the asset. The company shall be considered no matter one. Act. in order to have acquired debts, the creditvalue of the courier shall be credited at the time of the qualification following paragraph 1. 1. The extent to which the contestants are natural persons who would not have been taxed must have been deducted at the time of sale or inexcerpt at this time. Assets which, for one or more of the contestants have been acquired in the framework of nutrition, are treated by the inventory of the company ' s income as though they were acquired by this company as a source of nutrition. However, the company shall be deemed to have acquired these nutritional assets at the time of the qualification following paragraph 1. 1, to the extent that the participants would not have been taxed, have been deducted from the abstention of the assets at this point in time. If one or more of the participants have included unachieved profit and loss of securities, the securities shall be treated by the inventory ' s taxable income, as though these profits and losses were co-counted at the company. In the calculation of losses as referred to in section 5 A of the Asset Taxation Act, the yield and other benefits received by the participants shall be deemed to have been received by the company. The companies are succinating to the attendance-entitled deficit in accordance with the rules of the participants. § 12, and untapped deductible losses from previous income, cf. Article 9 (4) of the stock-tax system. 4, and section 43 (3). 3, the Danish exchange rate law, section 31 (1), 3, and section 31 A (1). 3, and the property section 6 (6) of the property. 3 when the deficits and losses are suffered as part of the transparency of the transparency or branch of the branch.

Paragraph 6. Confession of the ownership shares of the company shall be subject to the tax law of the shares in the stock market. The ownership of the owners shall be deemed to have been acquired for an amount equal to the tax value of the participant ' s share of assets and liabilities at the time of the qualification following paragraph 1. 1.

Paragraph 7. Ecodings for the owners of companies covered by paragraph 1. 1 is considered to be profit-making charges.

Paragraph 8. The company shall be included in the subject of paragraph 1. 1, the company shall be deemed to have been discharged and assets and liabilities, which are intact at the time of the transition, are sold to the commercial value at this time. Section 16 A, paragraph 1. 3, no. 1 shall apply mutatis mutis.

Niner. 9. In assessing the direct owners of the transparency units and branches of branches, foreign transparent entities and branches shall not be considered to be independent tax subjects, even if they satisfy the conditions laid down in paragraph 1. 1 if they are not considered to be independent tax subjects in their country of origin.

Paragraph 10. Paraguation 1 to 9 shall not apply to collective investment units (venture funds) which only invests in shares and so on subject to the equity tax law for the purpose of wholly or partially the acquisition of limited liability companies and analogues for the purpose of : participate in the management and operation of these. The following conditions are provided that the following conditions are met :

1) The venture fund must, in addition to investment commitments and unswolled cash deposits in financial institutions, and claims on ongoing services, cf. Section 12 B, received as payment for the sale of companies alone occuping shares, etc. covered by the issue of the equity tax law. Intent locks in a financial institution may be placed on a sealed account as collateral against the purchaser ' s warranty claims related to the selling of companies of the venture (s).

2) Indirect or indirect investment may be made directly or indirectly in companies which, together with any related companies, have to be made in accordance with any group affiliates. Tax Control Act, section 3 B, has less than 250 employees, and either has an annual balance of less than 125 million. DKK or an annual turnover of less than 250 million. DKK

3) None of the participants must possess more than 50%. of the capital or of the captor more than 50%. of the voices in the venture fund. Concerns and attendees, cf. Section 4 (4) of the exchange rate law. 2, and Article 4 (4) of the Asset Taxation Code. 2 is considered in this context for one participant.

4) The Venture Fund must have at least 8 participants. Concerns and attendees, cf. Section 4 (4) of the exchange rate law. 2, and Article 4 (4) of the Asset Taxation Code. 2 is considered in this context for one participant.

§ 2 D. If a legal person draws up shares, shares and similar securities, including convertible bonds, and the drawing rights of such securities in a group-related company (the acquiring company) to another group the company or trust fund (s) and the remuneration for this transfer entirely or partly consists of other than shares in the business or group affiliation, that part of the remuneration is considered to be the fee ; for profit. This does not, however, apply if the transferable company satisfies the conditions for the receipt of tax-free returns in accordance with section 2 (2). Paragraph 1 (c) or Article 13 (1). 1, no. 2, if the remuneration had been the yield of shares in the transferred undertaking immediately before the transfer. In addition, it shall not apply to the transfer of shares to an acquiring company, etc., which, before the transfer, was not affiliated with the transferable company, but which, as a result of a common boiling influence, shall be subject to the following. FIVE, TWO. .. The company will be involved in this company after the transfer if the company does not benefit from the transferor company or any other party to the company, etc., and so on. 1. Act. shall not apply, even if the remuneration is wholly or partly comprised of anything other than shares of the company or group of companies, to the extent to which transferable securities are equivalent to those of the transferable securities.

Paragraph 2. Where a legal person transfers shares, shares and similar securities, including convertible bonds, and the right of drawing rights to such securities for companies which, at the time of transfer, are essentially non-economic ; the risk of professional activity, cf. § 33 A, paragraph. 3, and the fee is partly made up of other than shares in the acquiring company or related companies, this part of the remuneration shall be considered to be the yield. The same applies if the transferee receives payment only in any other than shares in the business undertaking or the transferor of any such securities in one or more of these undertakings, by the transferee or the transferor of the transferor of such securities. except for the company in which the shares etc. are given in the case of paragraph 1, 2. and 4. pkt; shall apply mutatis muctis.

Paragraph 3. Commercial activity which, in the preceding three years prior to the transfer of shares and so on, has been acquired by a person or company, etc., which has the associated party in the body of the body of the body, is not included in the assessment ; by paragraph 2, cf. § 33 A, paragraph. 3. If a subsidiary company has been acquired from a group-related company within the preceding three years prior to the transfer of shares and so forth, business activity in the subsidiary shall not be included in the evaluation of the parent company in accordance with section 33 A (3). 3.

Paragraph 4. Remuneration in other than shares in the receiving company or related companies in connection with fusion or fission not covered by the Merger Tax Act shall be deemed to be dividend if the shareholder after the restructuring is owned by the company ' s shares in the company ' s share ; any of the depositing or receiving companies or undertakings. Paragraph 1, 4. pkt; shall apply mutatis muctis.

Paragraph 5. When it is established, when it is a group-connected company, the section 2 of the body of the body shall apply. A legal person equated to a company and an association, etc., which, according to Danish tax rules, is not an autonomous tax subject, but whose relationship is governed by company law rules, a company agreement or a association statute.

§ 3. Exempt from the taxable duty is :

1) The state and its institutions, cf. however, section 1 (1). 1, no. 2 d, 2 g, 2 in and 2 j.

2) The regions and the municipalities and regional and municipal establishments and institutions, cf. however, paragraph 1 7 and Section 1 (1). 1, no. 2 f and 2 h.

3) Anerent religious communities and religious institutions, established in connection with these, or to the people's church.

4) ports, including airports open to public transport, and gas and heating plants when access to supply from the plant is open to everyone in the area in which the plant works, all in the case of the marine or host ' s revenues, excluding those from the plant ; the normal interest rate of a possible deposit capital according to statute of statutes may be used solely for the purpose of the port or the shipyor. The conditions of 1. Act. are fulfilled, even though a port or airport carries out any activity that falls outside the purpose, provided that such activities are carried out in a subsidiary subsidiary.

4 a) Water supply companies, etc., which are not covered by Section 2 (2). Paragraph 1, in the organisation and economic situation of the water sector. It is a condition that delivery from the water supply company is open to all within the territory in which the company works and that the resupply company ' s income, except for the normal interest rate, of any deposit capital, according to the company ' s financial services, Statutes can only be used for the purposes of the company.

5) Schools, hospitals, hospitals, hospitals, State recognized reconvalescents, 24-hour institutions for children and young people and publicly approved facilities for children and young people, libraries under public supervision and public museums, all in the name of the public, self-employed institutions and revenues may be used exclusively for the purposes of the institution concerned. Schools and so on are exempt from tax duty, even though they have activities in the form of electricity and heat production which result in the conditions set out in 1. Act. are not met. However, the exemption shall not apply to the income of electricity and heat production.

6) The Land Construction Fund and housing organisations approved by the municipalities for the purpose of general housing, in so far as income, except for the normal interest rate, of a possible deposit-capital-according to the provision of the memorandum of association, shall be exclusively based on the basis of the provision of a single body of profit, may be used for the promotion of general housing or the like of the minister for approved purposes, including the sale of general family housing in accordance with Chapter 5 (a) in the law of public housing and supporting private cooperative housing, etc. Boligorganizations are exempt from : the tax obligation, even though they have activities in the form of electricity generation ; the warmth resulting from the conditions set out in 1. Act. are not met. However, the exemption shall not apply to the income of electricity and heat production. The conditions of 1. Act. are fulfilled even if the housing organisation or department of the housing organisation exercises activity that falls outside the one in 1. Act. the principal objective of this activity, provided that such activities are carried out in a subsidiary subsidiary. Rentable for purposes other than housing purposes covered by the main purpose of the housing organisation, or as the 31. December 2005 is covered by Section 6 (1). However, it is not a requirement for rental to be made through a subsidiary subsidiary of the general housing law.

7) Denmark's National Bank.

8) The occupational pension market.

9) Pension funds subject to the supervision of the law on the supervision of company pension funds or by law of financial activities. Other pension funds shall be exempt from the taxman, in so far as customs and tax administration is to be determined in each case.

10) The associations which are exempt under law no. 246 of 9. May 1917 on the auctions of farmers and housewives associations, etc., cf. law no. 80 of 4. March 1949. However, the exemption shall apply only to the income of the common statute of association of the organizations concerned, but not for the purposes of revenues of operations, renting or renting a firm or other business.

11) You, in the case of reorganisation mentioned by the Minister for the Housing Act, if they are approved by the minister, provided that in the Staff Regulations it is intended that the revenues, except for the normal interest rate, can be used only for the use of a possible deposit-capital-only for the use of the public body ; reorganisation purposes.

12) Occupational health insurance for the labour market.

13) The Payback Fund for the pay-holders.

14) The financial stability referred to in the Act of financial stability has been mentioned.

15) The urban renewal and housing law referred to the urban renewing companies, provided that the statutes are approved by the minister, provided that in the Staff Regulations it is intended that the revenues, except for the normal interest rate, of any deposit capital-can be limited solely to the benefit of the public ; are used to assist the local authorities and owners in preparing, organising and implementing urban renewal and housing enhancement, in accordance with the rules of the law on urban renewal and housing improvement.

16) The regional TV 2 companies.

17) The Investment Fund for the Development countries and the Investment Fund for Eastern Countries.

18) Work-market-related life insurance companies subject to Section 307 in the Act of Financial Regulation.

(19) Investment firms, cf. the section 19 of the asset tax law, except for account-leading investment associations, cf. Article 2 of the Act on the taxation of members of account-leading investment groups, except for UCITS with a minimum rate of taxation, cf. Section 16 C of the body of the body of the body of the body of the equation, section 16 A, paragraph 1. 1 and 2, as a company which is subject to 1. Pkton, however, from a company belonging to this country, however, it is subject to 15 pctines, unless the investment company ' s own shares are dividentised. 2. Act. does not include dividendividens received from an investment centre with minimum taxation, cf. Section 16 C, which only invests in claims covered by the exchange rate law and in derivatives financial instruments according to the rules of the Financial Directive, and the yield received from an investment centre with minimum taxation, cf. the section 16 C of the body or another investment firm, cf. 1. pkton, if these, following the articles of association, cannot invest in shares or shares in companies that are indigenous to this country. Understanding sums covered by Section 16 B (4) of the body of the body. 1, by the abstention of shares or units in a company, is subject to 15%. 4. Act. does not cover the payment of the investment in an investment institution with a minimum rate of taxation, cf. Section 16 C, which only invests in claims covered by the exchange rate law and in derivative financial instruments according to the rules of the Financial Authority, and the abstention of shares in a company that is after the statutes cannot be invested in shares or shares in other companies that are indigenous to this country. No matter three. and 5. Act. may be owned by the UCITS, the investment company or the company ' s shares in the management company that is responsible for the institution or management of the institution.

20) Payments Denmark.

Paragraph 2. You in section 1, paragraph 1. 1, no. 6, mentioned associations and so on at the income statement may deduct extractions for the statement of statutes which may be regarded as non-profit or otherwise non-profit-making. In cases where the association of other income has other income, the non-commercial income for the non-profit-making or otherwise non-profit-making use, prior to any part of the taxable income, shall be deemed to have been deemed to be non-profit or otherwise, for the purpose of this.

Paragraph 3. Detersions which associations and other organizations make to ensure or, subsequently, use for non-profit or otherwise use for non-profit purposes, shall be treated as specified in the referrals, as referred to in paragraph 1. 2. The Tax Minister shall lay down detailed rules on the accounting requirements for the execution, including that it is effectively extraneated from the other means of association and that management is obliged not to make the appropriations available at the disposal of : the other company of the association. Where the amounts are used for non-profit or otherwise non-profit-making or otherwise, the amounts shall have to be the amounts of 25% in addition to the above. are included in the calculation of the taxable income for the income in which they are used. If the other income of the association has been negative, the amounts must be taxed with the tax rate applicable to the income concerned.

Paragraph 4. The people in paragraph 3. 2 and 3 given rules shall also apply to the rules laid down in section 1 (1). 1, no. The stock companies and other companies referred to in paragraph 1 and other companies shall be subject to the general interest of an association and so on by non-profit-making or otherwise, of the general interest of the shares. Income, income in an income earned by the limited liability company, etc., shall be deemed to have been earned in the same income by the association and so on which shares the shares and shares of shares in the shares of shares in stock or other shareholdings. which immorse the association and so on which owns the stock or other capital chapter.

Paragraph 5. The rules of paragraph 1. 1 on the exemption from the tax obligation shall not apply to the tax duty provided for in Article 2 (2). 1 (c) and the tax on the income of the coal-carbon tax, as regards the income referred to in Article 4 of the law.

Paragraph 6. An undertaking of the one in paragraph 1. 1, no. The provisions of this Article shall be exempt from the tax obligation, irrespective of the fact that the restriction on the use of the operation of the operation of the undertaking is not included in its statutes, provided that it is deemed to have been excluded from the statutes of the undertaking. It is a condition that, in the winding-up proceedings, no more than the deposited capital shall be disbursed, and that the undertaking complies with the provisions of paragraph 1. 1, no. 4, the restriction on the use of the undertaking ' s revenue.

Paragraph 7. Municipalities are the taxable income of commercial activities by commercial enterprise and other business activities which are either covered by Section 2 (2) of the power supply. 1, on power supply or exempting from paragraph 2 (2). 4, from the provisions of the electricity supply law (power business), cf. however, paragraph 1 8, and Section 1 (1). 1, no. 1 and 2 e. However, the tax obligation does not cover the income of the production of electricity and heat on the burning of waste. If the municipalities are in commercial activities after 1. Act. producing electricity and heating in cogeneration shall include the income of the taxman as well as heating production. The tax shall also include profit and loss of Disposal, abstention, or abandonment of assets that have, or have associated with, the power-nutrition business. Possession of shares, etc. in electricity companies shall not be regarded as electric business after 1. Act.

Paragraph 8. For municipalities that want to go into taxation in accordance with paragraph 1 (1). 1, no. 2 f, from taxation in accordance with section 3 (1). 7, find Section 5 C (3). 2, similar use with regard to assets and liabilities, both before and after the transition is covered by the taxation. The values are set out in section 35 O, paragraph 1. 6, replace the summary summaries referred to in section 5 C (3). 2. Section 5 D shall apply mutatis muctis to other assets and liabilities.

Niner. 9. A company may choose to go to tax freedom in accordance with paragraph 1. 1, no. Eighteen, with effect from the beginning of the product, that such statutes are made, that the conditions of the freedom of taxation are fulfilled, irrespective of the fact that the conditions are not met by the start of the income year. It is a condition that the company in that income does not pay dividens to the owners.

§ 3 A. For a limited liability company as referred to in section 1 (1). 1 if the capital of the entire income year is fully owned by a life assurance undertaking, a pension fund or a pension fund, taxable in accordance with the provisions of Article 1 (1) of the Pension Codee Code. 2, and whose assets on average over the income year of at least 90%. in the case of real estate, the rules shall apply in paragraph 1. 2-7. With full direct ownership, full indirect ownership by means of a life assurance undertaking, a pension fund or pension fund, taxable in accordance with pension tax law or of a limited liability company as referred to in 1. Act. A majority of the taxable age of Article 1 (1) of the Pension of Pension Act. 2 carrying out activities on the basis of a common agreement shall be deemed to constitute a single undertaking.

Paragraph 2. In the assessment of whether a stock company ' s assets for at least 90% are made up of solid property, be disregarded from the value of shares in another limited liability company which is directly or indirectly owned by a life assurance undertaking, a pension fund, or a pension fund that is taxable in accordance with the tax law of the Pension Fund. Instead, the assets are involved in the other limited liability company.

Paragraph 3. That is a condition that it is in paragraph 1. ONE, ONE. .. The company concerned shall have the same financial year as the life assurance undertaking, the pension fund or the pension fund.

Paragraph 4. Owes the item in paragraph 1. ONE, ONE. in the case of a life insurance undertaking, a pension fund or pension fund, income earned in the income year in the income year shall be deemed to have been earned in the same income by the life assurance undertaking ; the pension fund or pension fund directly or indirectly owned by the stock company. Owes the stock company in full by a majority of the taxable age of section 1 (1) of the Penalty Code. 2, cf. paragraph ONE, THREE. pkt. shall mean an income of the average Equity of income earned in the income of the income year in the same income from each of the owners, cf. Three. Act. If an owner has opted for Section 13 F, income in the income year is earned by the stock company, to the owner's income after Section 13 F.

Paragraph 5. The life assurance undertaking, the pension fund or the pension fund, shall be liable for the tax, including the residual tax, supplement and interest, of the income provided for in paragraph 1. 4 shall be applied to the provisions of paragraph 1. ONE, ONE. pkt., referred to as limited liability company, cf. however, section 31 (1), 6, section 31 A, paragraph. 4, and the company shall be liable for the solidarity of this tax.

Paragraph 6. Deposits in a limited liability company as referred to in paragraph 1. ONE, ONE. ptankers which are untapped for the purposes of switching to taxation under this paragraph shall be deducted pursuant to section 12 in excess of the company ' s company. The deduction shall be deducted prior to deduction of the income concerned in the life insurance undertaking or other limited liability company as referred to in paragraph 1. ONE, ONE. Act.

Paragraph 7. Loss in a stock company as referred to in paragraph 1. ONE, ONE. provisions to be deducted from the use of the provisions in force in respect of the profit of the stock companies in question. The deduction shall be deducted before the loss of the income concerned in the life assurance undertaking or other limited liability company as referred to in paragraph 1. ONE, ONE. Act.

Paragraph 8. Where a real estate company is transferred to taxation under this paragraph, a tax liability corresponding to the tax value of the taxable profit which would arise if the company ' s fixed properties were sold to the trading value ; the time of the transition. The tax value is calculated by the tax rate that is calculated in accordance with section 17 (3). Firstly, the first income is taxing in accordance with this paragraph. To the extent that the company is owned by a pension fund or pension fund that is not taxable by that law, and the stock company is affixed to immovable property as set out in 1. PC, the tax obligation shall be treated as a tax charge to be paid by the company for the income concerned. If the abstention of the property is less than the commercial value of the changeover to taxation under this paragraph, the sum of the payment shall be used in the calculation of the tax burden. The tax obligation shall lapses when the company ceases to be covered by this Section or Property of the Property.

TITLE II

Entrement of income tax (income)

§ 4. The taxman in this country and associations, etc., not exempt from the tax duty after paragraph 3, shall enter at the time of the foundation, cf. however, paragraph 1 3, 4 and 5.

Paragraph 2. The tax intake shall take place for the first time on the income of the product, cf. section 10, which is the first income period, or replace, without regard to its length. The first income period may be up to 18 months, unless otherwise provided by Section 10 (2). 5.

Paragraph 3. In the case of companies and associations, etc., the time before the time when the company and so on becomes a resident in this country, the taxman shall enter into the country where the company and so on will become a resident in this country.

Paragraph 4. In the case of a taxable transfer of a personal owned company to a newly established equity or liability company, in which the owner of the company becomes the owner of all shares or parties, cf. Five. PC, the owner may decide that the transfer is concerned with the two in the case of the two. Act. whereas, in the case of the Foundation ' s financial year, the fiscal effect from the cutting date must be attributed to the undertaking, provided that the company ' s financial year runs from that date and the date of expiry of the owner ' s last year ; normal income before the foundation. Add fiscal effect from the cutting date, the commercial value of the company's assets and liabilities per. the date on which the balance of ownership of the owner and the company ' s assets and liabilities, and the company are counting on the revenue and expenditure of the undertaking, the revenue and expenditure of the undertaking, which may be considered to relate to the company, should they be considered as : the transfer of the establishment actually occurred on the date of the commercial value by the date of the commercial value. this date. It is a condition for the transferability of a tax retroactive effect that the Foundation shall take place no later than six months after the date of the selected date, and that the owner shall submit a copy to customs duties within one month after the date of the date of its entry, the tax administration of the documents prescribed by company law and documentation for the registration of the company in the Enterprise and the Corporate Protection Agency, in accordance with the provisions of the Company and Corporate Authority. however, paragraph 1 6. The tax obligation for the company shall enter the date on which the transfer is to be made in accordance with 1. Act. conferred. In the case of a taxable transfer of a personal owned company, with multiple owners to a newly-arched share or party stock, find 1. -4. Act. equivalent use, provided that the owners are remunorate in relation to their shares in the person owned by the person concerned.

Paragraph 5. In the case of a company ' s taxable undertaking by a company to a subsidiary in which shares or parties become the owner of all shares or parties, the company may decide that the transfer will, in so far as they are concerned, As for the two of them. Act. whereas, in the case of the Foundation ' s opening balance, the tax effect of the cut-off shall be attributable to the fiscal effect of the opening balance of the subsidiary, provided that the subsidiary financial year runs from that date and the date after which the date is expired ; the last normal income of the stock or the party undertaking before the foundation. Add fiscal effect from the cutting date, the commercial value of the company's assets and liabilities per. this date for the purpose of the balance of the assets and liabilities of the undertaking and the subsidiary undertaking of the company ' s assets and liabilities, and the subsidiary of its income from the income statement, the revenue and expenditure which may be regarded as being regarded as having been deemed to have been : in the case of the subsidiary, if the transfer of the undertaking actually had occurred on the date of the commercial value by the date of the commercial value. this date. It is a condition that the transferability may be attributed to the tax retroactive effect that the Foundation shall take place within six months of the date of the selected cut-off date and that the company shall submit a copy to customs duties no later than 1 month after the date of its constituent ; the tax administration of the documents prescribed by company law and documentation for the registration of the company in the Enterprise and the Corporate Protection Agency, in accordance with the provisions of the Company and Corporate Authority. however, paragraph 1 6. The certificate of duty of the subsidiary party shall enter the date on which the transfer is to be made in accordance with 1. Act. conferred.

Paragraph 6. Customs and tax administration may disregard the expiry of a period of one month in paragraph 1. 4 and 5.

§ 4 A. If a company or association, etc. will be fully taxable in accordance with section 1, or if a corporation or association etc. in accordance with the provisions of a double-taxation agreement is established here in the country, assets and liabilities shall not be regarded as in : already in the Danish tax rate, obtained at the time of the acquisition of the commercial value at the time of the transfer, cf. however, paragraph 1 2. No replacement amount shall be fixed on goodwill or any other immaterial assets referred to in Section 40 of the Depreciation Act, to the extent that they are the work of the company itself ; the best in relation to the purchase price can be counted at a maximum of a sum ; corresponding to the difference between the sales sum and the commercial value at the time of withdrawal under Danish taxation.

Paragraph 2. Depreciation-entitled assets are considered to be acquired on the actual acquisition time, and they are considered to be acquired for the actual acquisition sum by the maximum of Danish rules until the time of the date of the transfer. For this calculation, the rules shall be applied at the time of the transfer. However, the assets shall be regarded as acquired for the trading value at the time of the transfer, where this value is less than the value calculated in accordance with 1. and 2. Act.

Paragraph 3. Recycled depreciation of assets considered offenders under Danish taxation may not exceed the amount by which the sum of the depreciation of the tax shall exceed the amount of the actual value added after the tax ; participation under Danish taxation. The only thing in relation to the purchase price can be counted at a maximum of a sum equal to the difference between the sales sum and the commercial value at the time of withdrawal under Danish taxation. For assets written in accordance with the hymometer, the sum of the sum to the written value shall be assumed at the time of the time of departure, with the addendum of revaluation and profit after 1. and 2. Act.

Paragraph 4. Expenditure held before the time of the transfer may be deductible from the taxable income only if, at the time of the time, the deduction was deductible for these expenditure pursuant to section 2.

Paragraph 5. Paragrace1 to 5 shall apply mutatis mutias to undertakings and associations, etc., subject to the taxable of sections 2 and not immediately prior to the taxable of Clause 1 or the Fund for the Fund ' s Code.

§ 5. In the case of the country belonging to companies and associations, etc., the taxable shall continue until the time of the solution. For switching to taxation in accordance with section 1 (1), 1, no. 6, or tax exemption from Article 3, the taxable duty shall continue in accordance with the applicable rules until the time of transition or the derogation.

Paragraph 2. Expires the usual income for a company and so before 31. In the calendar year in which the income of the income is replaced (back on the income of the income), the solution as referred to in paragraph 1 shall be as referred to in paragraph 1. 1 site after the usual year of earnings, but before the end of the calendar year, the final income shall be the entire period from the beginning of the income year and until dissolution takes place.

Paragraph 3. The liquidator or Management if a liquidator is not selected or discharged must within 1 month of the solution transition or the exception, cf. paragraph 1, submit a notification to customs and tax management with the income of the final income from the said product. Expires the notification deadline before the end of the deadline for the tax return on the nearest preceding income, cf. Tax Control Act, section 4 (4). The latter period shall be truncated to the expiry of the time limit for notification. The customs and tax administration may, at the request of the Member of the Commission, grant a postponement with the deadline for notification if special circumstances are In the absence of notification, the person or persons responsible shall have a fine fixed by customs and tax administration unless this or those responsible for the trial are decided upon due process. The submission of the notification to the said account may be imposed on the imposition of daily penalties, the amount of which is fixed by customs and tax administration. The fines are to the treasury.

Paragraph 4. Trangang, etc., cf. paragraph 1, put an end to the business and sale to commercial value of the assets and liabilities that are intact at the company or association and so on at the time of the transition.

Paragraph 5. If a company or association, etc. shall cease to be taxable in accordance with section 1, or if a company or association etc., in accordance with the provisions of a double taxation agreement, will become a country of Greenland, Greenland or Faroe, or the other. 1-3 and the equal to section 16 A (3) of the body. 3, no. 1, corresponding use. Tax payment after 1. Act. for a natural person, cf. Section 16 A (3) of the body of the body. 3, no. 1 (c) shall be reduced to the extent that the natural person has paid taxes on the benefits and losses of the shares in the company as a result of the section 38 and 39 of the asset tax on the asset.

Paragraph 6. In the case of taxable associations, etc. as referred to in section 1 (1). 1, no. 6, find paragraph 1. 1-4 similar use shall apply where the association, etc. in whole or in part, ceaceto operate in a business.

Paragraph 7. If a company or association, etc. shall cease to be taxable in accordance with section 1, or if a corporation or association etc., in accordance with the provisions of a double-tax agreement, will be resident abroad, Greenland or Faeroe, shall be deemed to have been deemed to be a company or association ; assets and liabilities which are not still subject to Danish taxation, for the dispose of the transfer at the time of the leaving. The sales sum is set to the commercial value at the time of the leaving.

Paragraph 8. Paragraph 7 shall apply by analogy if a European company (SE-Company) or a European Cooperative Company (SCE), which is not taxed in accordance with section 1 (1). 1, no. 3, shall cease to be taxable in accordance with section 1 as a result of the company moving its registered office to a country that is a member of the European Union.

Niner. 9. Paragrics 1 to 8 shall not apply when applying to or termination of taxation after paragraph 3 (1). 4, or § 3 A. 1, 2 and 4 to 8 shall not apply to cases covered by Section 5 F.

§ 5 A. If such a change is made, a company or association etc. shall be transferred to taxation in accordance with section 1 (1). 1, no. 3, from taxation in accordance with other rules in section 1, the taxable shall continue in accordance with the applicable rules until the time of the transition. For switching to taxation in accordance with section 1 (1), 1, no. 3, from taxation in accordance with section 1 (1). 1, no. 4, the change shall be deemed to have happened at the end of the income in which the transition occurs. Section 5 (5). 2 shall apply mutatis mutis.

Paragraph 2. For a change as referred to in paragraph 1, 1 the Management Board shall, within one month after the change, submit a notification to customs and tax management with the statement of income for the final income. The rules in section 5, paragraph 1. 3, shall apply mutatis mutis.

Paragraph 3. Transition as referred to in paragraph 1. 1 equate with the cessation of activities and sales to commercial value of the assets and liabilities that are intact at the company or association and so on at the time of the transition.

§ 5 B. If such a change is made, a company or association, etc., shall be transferred from taxation in accordance with section 1 (2). 1, no. 3, to taxation in accordance with other rules in section 1, except in section 1 (1). 1, no. 6, the changeover shall take effect on the undertaking ' s or other tax obligations from the expiry of the corresponding revenue.

Paragraph 2. For a period referred to in paragraph 1, Paragraph 5 shall apply mutatis muy; 1.

Paragraph 3. For a period referred to in paragraph 1, 1 the balance must be made of the assets collected by the company or association, etc., subject to the tax on paragraph 1 (1). 1, no. 3, or equivalent taxation. The amount shall be carried out as the commercial value of the assets and liabilities of the company or of the association, at the end of the shift, deduced from any paid capital. If the company or association has previously been subject to taxation in accordance with other rules in section 1, the amount shall be charged as the difference between the commercial value of the assets and liabilities of the undertaking and the liabilities in the transition and trading value at the time of entry into : taxation in accordance with section 1 (1). 1, no. 3, or equivalent taxation. From the trade values, a possible payment of other capital shall be drawn up. The amount shall be indicated by the selle declaration for the transitional year.

Paragraph 4. The one under paragraph 1. 3 the amounts are taxable income for the company or the association, etc., shall not, however, be introduced as the company or association, following the transition, carries out the outlines referred to in section 16 A of the body of the body, make the release of : the liquidation of liquidation in the calendar year in which the company or the association and so on end is resolved or pay for the acquisition of their own cooperative evidence. Any grant granted by the company or association and by group companies shall be included in the outloins and so on. Section 31 C, for which the company or association directly or indirectly has an influence over, to corporate companies, which the company or association does not have a bossy influence over. The first and so on which is carried out after the transition is considered to be the first to deduct from the following paragraph. 3 opted amounts.

Paragraph 5. The company or association, etc., shall provide information on the part of the part of the party in accordance with paragraph 1. 3 collected amounts still not taxed in accordance with paragraph 1. 4.

Paragraph 6. In the event of a subsequent transition as referred to in section 5 A, the taxation of the following paragraph shall end. 3 opted amounts. However, the taxation of the remainder of the amount shall be reentered in cases where a transition is subsequently referred to in paragraph 1. 1, a merger referred to in Article 12 (2) of the Merger Tax Code. 1, no. 3, or a transformation referred to in section 14 of the Merger Tax Code.

Paragraph 7. It is the responsibility of the governing board of associations taxed in accordance with paragraph 1 (1). 1, no. 3, at the same time as the self-rendering of the tax return, the amendments which have occurred during the financial year in the company ' s activities or in its provisions for the purposes of the association or in its provisions for the purpose of overshooting or disintegrating, as well as the Board of Directors, if the association ' s association ; The turnover of non-members is more than 25%. of the total turnover.

Paragraph 8. 4, 2. -4. a point shall not apply to the extent a association is covered by section 1 (1). 1, no. 4, perform the charges referred to in Section 16 A of the body of the body, not exceeding the taxable income of the association in accordance with the income of the tax in the preceding revenue. Prevention or other charges may be made other than those referred to in section 16 A of the body of the body of the body of the body of the body of the body of the body. 4, 2. 4. PC, apply for this part.

Niner. 9. It is the responsibility of the governing board of an association that is taxed in accordance with paragraph 1 (1). 1, no. 4, at the same time as the submission of the self-specification to indicate the extent to which the extractions are subject to paragraph 1. 4 or 4. 8.

§ 5 C. If, outside the cases referred to in section 5 A, 5 B and 5 F, such a change shall be made for a company or association that taxation for future must be carried out in accordance with other rules in section 1, except in section 1 (1). 1, no. 6, end to date, the provision in section 5 B (s). 1, corresponding use.

Paragraph 2. Formuegos, which are intact at the company or association at the time of the change, are deemed to be acquired at the times and for the fields of acquisition and purpose for which they were originally acquired. Tax depreciation and depreciation of stock and farm stock livestock holdings, which have been made prior to the change, cannot be modified with effect on the company ' s income ' s income statements for subsequent financial periods. Any reference to an investment fund that is not used in the change shall be deemed to have been carried out in the earners in which they have been originally made.

§ 5 D. If a company or association etc. is removed from the tax duty in accordance with section 3 (3), 1, no. 1 18 to be taxable in accordance with Article 1, the changeover will affect the taxable duty of the company or association at the time of the commencement of the undertaking, the taxman, or at the time of which the establishment is considered to be : taxable. The tax intake shall take place for the first time on the income of the product, cf. section 10, which is the first income period, without regard to its length. The first income period may be up to 18 months.

Paragraph 2. In the income that is the basis for initial tax recruitment, machinery, equipment and other similar operating methods and ships, such as the company or association etc., have before the transition to a tax obligation, in the balance of the balance, by the rules of the depreciation of the law ; with their trade value at this time, conversely into cash value.

Paragraph 3. On buildings that are depreciated after the depreciation of the depreciation, and installations serving only such buildings and acquired or completed prior to the transition to the taxable amount, depreciation shall be carried out on the basis of the value by which : the building or installation is included in the property value of the most recent estimations prior to the revenue that is the basis for the initial tax recruitment, or in cases where no property value is employed by the commercial value per year ; Lately 1. Oct in advance of the income that is the basis for the first tax recruitment.

Paragraph 4. On installations that are depreciated to the section 15 (5) of the Depreciation Act. 2 and acquired or completed prior to the changeover to the taxpayer, shall be carried out on the basis of the value by which the installation is estimated to be included in the property value at the latest estimations prior to the income that is the basis for it ; initial tax recruitment, or in cases where no property value is employed, the value of the commercial value per year ; Lately 1. Oct in advance of the income that is the basis for the first tax recruitment.

Paragraph 5. For expenditure on rebuilding, improvement or accommodation of rented premises which are depreciation due to section 39 of the Depreciation Act and held prior to the transition to the taxable duty, depreciation shall be carried out on the basis of the costs incurred in repayment. to the cash value at the time of the changeover to the tax duty reduced by the depreciation that could have been made since the acquisition wound following the rules at the time of the date of the transition to the taxable duty.

Paragraph 6. On goodwill and other immaterial assets that are depreciation-entitled under the section 40 of the write-down 40 and acquired before the transition to the tax duty, depreciation shall be made on the basis of the acquisition sum to be converted into cash value at the time in the form of the changeover to the tax burden, reduced by the depreciation that could have been made since the acquisition wound following the rules at the time of the transition to the taxable duty.

Paragraph 7. On other depreciation-entitled assets acquired before the transition to the taxable duty, depreciation is made on the basis of their commercial value at this point in conversion to cash value.

Paragraph 8. In the case of profit or loss on the income tax law of shares acquired before the transition to the tax duty, the exchange rate shall be replaced by the duty of the exchange to the taxable amount, instead of the purchase price. However, the company or the association, etc., may choose to place the purchase price for reason. The choice is to be made for all the shares in one. In the case of profit or loss, the actual acquisition time of the stock is used.

Niner. 9. In the case of profit or loss after the property tax law of fixed property acquired before the transition to a tax duty, the property value of the most recent estimations prior to the income that is the basis for the first product shall be the first to be assessed ; the rate of employment, or in cases where no property value is employed, the value of the commercial value per year ; Lately 1. Oct in advance of the income that is the basis for the first tax recruitment, rather than the sum of the purchase price. However, the company or association, etc., may choose to add the purchase price to the cash value for reasons. In the case of profit or loss, the actual purchase of property shall be used, however, in order to be considered as acquired at the beginning of the product concerned as acquired at the beginning of the product ' s property as acquired at the beginning of the income tax. there is the basis for the first tax recruitment.

Paragraph 10. In the case of profit or loss after the exchange rate applicable to claims and debts acquired respectively before the transition to the taxable duty, the exchange rate shall be set at the time of the changeover to the tax-site, instead of the purchase price ; respectively, the value of the debt on the debt. However, the company or association, etc., may choose to place the purchase of the purchase of the sum, respectively, on account of the payment of the debt. The choice shall be taken together for all claims and obligations under one. In the case of profit or loss, the actual purchase of the claim or debt shall be used.

§ 5. E Activate that per. 31. In December 2004, investment funds linked to Classes III life insurance have been deemed to be acquired by the life assurance undertaking on 1. 1 January 2005 to the accounting value of 31. December 2004. Fiscal provisions per year. 31. In December 2004 on savings in the investment funds concerned, it shall be used as provisions per year. 1. In January 2005, in the calculation of the taxable income for 2005 and subsequent years.

§ 5 F. The transition shall not affect the duties of the company and so on from the expiry of the corresponding revenue in the following situations :

1) If a company, etc. covered by section 1, will be transferred to a minimum rate of taxation, cf. section 16 C of the body or an investment firm covered by Section 3 (3). 1, no. 19.

2) If an UCITS with minimum taxation, cf. Section 16 C of the body shall be transferred to a different provision in section 1 or to be an investment company subject to section 3 (1). 1, no. 19.

3) If a stock-based investment institution with a minimum rate of taxation, cf. Section 16 C of the body of the body, section 21, is transferred to a bond-based investment institution with a minimum rate of taxation, cf. section 16 C of the body of the body, section 22 of the body of the body.

4) If an investment company is covered by section 3 (3). 1, no. 19, to be an investment centre with minimum taxation, cf. Section 16 C of the body.

5) If an investment company is covered by section 3 (3). 1, no. 19, surpassed to the fall in section 1.

Paragraph 2. The transition referred to in paragraph 1. 1, no. 1-3, put an end to business and sales to commercial value of the assets and liabilities that are intact at the company or association and so on at the time of the transition.

Paragraph 3. For the time being referred to in paragraph 1, 1, no. 4 and 5, assets and liabilities shall be deemed to have been purchased for the commercial value at the time of the transition.

Paragraph 4. For the time being referred to in paragraph 1, Paragraph 5, paragraph 5, shall apply. 3, use.

Paragraph 5. Transition from a debt-based investment institute with minimum taxation, cf. Section 16 C and Asset Taxation Act, section 22, to an equity-based investment institution with minimum taxation, cf. The section 16 of the body of the body of the body of Section 21 of the body of the body of the same as Article 21 shall not affect the institution from the end of the product concerned until the end of the product concerned The assets and liabilities of the Foundation shall be deemed to have been acquired on the initial purchase time and to the original purchase price.

Paragraph 6. For the period referred to in paragraph 33 (3) of the Asset Taxation Code, 9, the stock acquired on the original acquisition time and to the original acquisition sum shall be considered to be the stock.

§ 6. For companies and associations, etc., where they are registered abroad and which, pursuant to section 2 (2), are based. 1 (a) (b) or (f) shall be subject to a limited tax obligation in this country, the taxable duty shall be entered at the time of the commencement of the undertaking ' s duty of the taxman. The tax will take place for the first time on the income that the initial income period represents or replace, without regard to its length. The first income period may be up to 18 months.

§ 7. When foreign companies and associations, etc., have their home abroad and as provided for in Article 2 (2). 1 (a) (b) or (f) shall be subject to limited tax obligations in this country, dissolve or ceases to operate taxable activities in this country, the taxable duty shall continue until the time of the solution or the termination. The rules in section 5, paragraph 1. 2 and 3 shall apply mutatis mutis.

§ 7 A. Company in this country shall not be deemed to have been abandoned when the establishment of the undertaking ' s stock, machinery, operating equipment and equipment, etc., has been carried out.

TITLE III

The taxable income

§ 8. The taxable income is set up according to the general rules of the tax bill, provided that, according to their content, they are applicable to the companies and associations, etc., in accordance with the provisions of this Act. however, section 8 A, paragraph, 2.

Paragraph 2. The taxable income shall not include revenue and expenditure relating to a fixed operating location or a permanent property situated in a foreign state, in the Faroes or Greenland, cf. however, section 31 A. As income from fixed operating premises and property, income as referred to in section 2 (2) shall be deemed to be an income. 1 (a) and (b). 1. Act. does not include an income of international ship and air carrier or cases where the source of the source of which is fraudulled under the right of a double-tax agreement or other international agreement with Denmark. No matter what. Act. is taxed a company of positive income that would fall within the CFC tax in section 32 if the fixed operating site had been a subsidiary. As well as the assessment of whether the CFC income is to be included in the calculation of the CFC income, the income-baring principles shall be applied to firm operating sites. Section 32 shall apply mutatis mutis, other than paragraph 1. 7, 1. pkt., and paragraph. 10. In the case of immovable property in a foreign state, on the Faroe Islands or in Greenland, where the purchase price is reduced according to the section 6 A and 6 C of the property tax, the part of the proceeds relating to property located in Denmark shall be counted ; in the calculation of the taxable income.

Paragraph 3. Any company may be able to do so, 2 each year choose to include income from all fixed operating locations in foreign states, Faeroes or Greenland, to which mobile drilling is associated. Negative income after 1. Act. may only be resisticounted in equivalent positive income for the following years. In the selection and selection of 1. Act. find paragraph 1. 4 respectively. 5 corresponding use.

Paragraph 4. The transfer of assets and liabilities which are not already covered by the Danish tax, internally within the company, to a firm operating location or principal office in Denmark shall be treated as a group of undertakings. Section 8 B shall apply mutatis muth. The transfer of assets and liabilities, which after the transfer is no longer covered by the Danish tax, internal in the company, to a fixed farm or a principal office of a foreign state, on the Faroe Islands or in Greenland, on sale to conglomnials to the trading value at the time of transfer.

Paragraph 5. Transfer assets and liabilities internally within the company to a firm operating site or a principal office of a foreign state, in the Faroes or Greenland subject to international taxation, cf. Section 31 A, and shall terminate international co-taxation at a later date when the assets and liabilities are intact with the company, but outside Denmark, the assets and liabilities shall be regarded as sold to the commercial value at the time of the termination of the sale ; voluntary co-taxation. The Danish tax shall be reduced in accordance with the rules of section 33 (3) of the equation. Article 1 and (2), or in accordance with the rules of the double-taxation agreement with the tax that the State, the Faroe Islands or Greenland, could have incurred capital gains if the asset or the passivity had been passed at this time.

Paragraph 6. Income in a permanent farm place of a foreign state, on the Faroe Islands or Greenland, as a profit made by the operating site, including in its internal transactions with other parts of the undertaking which the operating location is a part of, if it had been a separate and independent undertaking engaged in the same or similar activity under the same conditions or similar conditions, having regard to the operations carried out, the assets being used and the risks to be taken by it ; the undertaking concerned through the operating spot. Where a double tax agreement has been concluded with the foreign state, the Faroe Islands or Greenland, where the fixed operating location is situated and the Article on the profit of the business organization is not formulated in accordance with 1. on point, however, the income in the operating facility is discharged in accordance with the provisions of the relevant Article.

Paragraph 7. For Energinet.dk, as mentioned in paragraph 1 (1). 1, no. 2 g, and for Energinet.dk's subsidiaries, additional rules apply in sections 13 D and 13 E.

Paragraph 8. For the sections referred to in section 1 (1). 1, no. 3, mentioned cooperatives shall apply to the rules in section 14 to 16 A.

§ 8 A. Taxable merger between companies and so on in accordance with the rules in force shall have fiscal effect from the date on which the merger is definitively adopted by the participating undertakings, etc.

Paragraph 2. The companies, etc., may, however, decide that the merger is concerned with the two in the case of the two. Act. whereas, in the case of the concentration, the fiscal effect from the cutting date of the concentration must be attached to the receiving party, provided that this date coincides with the date of the cutting date of the receiving company, financial year. Add the tax effect of the concentration from the cut-off date shall be added to the value of the incoming company per caption. the date, as reflected in the remuneration of the shares or the parties involved in the incoming company, for the purpose of the withdrawal of the withdrawal sum of the depositing company and the acquisition of the company ' s acquisition sum for the assets and liabilities and the liabilities, and the receiving party shall include revenue and expenditure on the income and expenditure which may be considered to be related to the company, provided that the concentration of companies had actually taken place on the cutting date of the values per unit ; this date. Should the income of one of the participating undertakings in the concentration be set up in accordance with the rules laid down in section 31 (1). 5, as a result of the concert connection, cf. Section 31 C has been discharged or established before or in connection with the merger, the time of termination of the group connection, regardless of 1, shall be used. and 2. Act. as a cut-off date for the company concerned. In cases covered by 3. Act. shall not be required to have the same fiscal cut-off date of the merging companies. It is a condition for the concentration to be attributed to the tax retrospective by 1 month after the day on which the concentration has been adopted in all the participating undertakings, etc., submits a customs duty to customs duties, the tax administration of the documents established in the framework of the merger, together with evidence that the merger has been definitively adopted by the participating undertakings, etc., cf. however, paragraph 1 3.

Paragraph 3. Customs and tax administration may disregard the expiry of a period of one month in paragraph 1. 2.

§ 8 B. Acquirevaluing assets from a group-related company, cf. Section 4 (4) of the exchange rate law. 2, without the transfer of any derivatives or foreign taxation of any revaluation, gains or losses, or foreign taxation at the hand-over has been deferred, the transferee shall enter the transferable party ; company's acquisition sums and acquisition times. The depreciation-entitled assets shall be deemed to have been written by a maximum of Danish rules until the time of acquisition. § 4 A, paragraph 1 TWO, TWO. and 3. pkt; shall apply mutatis muctis.

Paragraph 2. In the section 40 of a group-related company, the goodwill or other immaterial assets of the company, as mentioned in the depreciation Act, is provided in the section 40 of a group Section 4 (4) of the exchange rate law. 2, and are the activities of the transferable company or other group affiliates, the assets shall be deemed to be under the assets referred to in paragraph 1. Paragraph 1 shall be responsible for the establishment of the taxable income for the construction of the company being acquired.

Paragraph 3. § 4 A, paragraph 1 3, shall apply mutatis mutis to the assets covered by paragraph 1. One and two.

Paragraph 4. Paragraph 1-3 shall apply mutatis mutias to assets such as a company or association and so on shall be acquired before it becomes taxable in accordance with section 1 or 2.

Paragraph 5. However, the provisions of paragraph 1-4 shall apply, although Danish taxation has not been done in the case of full Danish taxation resulting from the amount of profit added to the difference between the sum and the value of the commercial value at the time, in the case of withdrawal under Danish taxation. To the extent that taxation has been achieved, the acquisition of the acquisition shall be increased by the profit made by the transferor in the income of the taxable income.

§ 9. The companies and associations, etc., referred to in section 1 (1). 1, no. 2 f and 6, section 2, section 1 (a) (b) and (f) and section 3 (3). 7, in the case of deducisation of the taxable income, only deduces of expenditure relating to income sources may be deducitable from the income of the income of their income. Companies or associations, etc., covered by Section 1 (1). 1 which is considered to be resident in a foreign state, the Faroe Islands or Greenland, in accordance with the provisions of a double-taxation agreement, can only deduction expenditure relating to revenues to which Denmark may tax.

Paragraph 2. They are in accordance with the rules in paragraph 1 (1) 1, no. 3 a, taxable use associations may deductim from the taxable income from dividends, payment or bonuses granted to the members of the financial year in question. It is a condition for doing so that Members are not tax-free of the dividend and so on in accordance with Article 16 A (4) of the equation. 4, no. It is also a condition for doing so that the dividend and so forth shall be definitively fixed by the Union's Association at the latest six months after the beginning of the financial year. If the dividend and so forth shall be increased after the expiry of this period, the amount by which the dividend for the financial year in question shall be increased shall not be deduct from the deduct of the taxable income for the income concerned. The increase cannot be reduced to income from the income statement for future incomes.

Paragraph 3. The people in paragraph 3. 2 restrictions on access to deduction for divisive and other countries shall not include any discount benefits.

§ 10. The taxable income is being rebuilt on the basis of income in the income year. The income is the calendar year. If the tax duty is only part of the year, the income year is this part. The company or association and so on may select a different income from the calendar year (staggered income). If there is a company or association and other revenue other than the calendar year, the taxable income shall be discharged in accordance with the rules applicable to the calendar year in which the advance income takes place. An impudable income of an impudable income can begin at the earliest possible second. In April of the calendar year preceding the calendar year in which the back income is replaced, replace. A forward-looking income can be at the latest beginning on 1. In the calendar year in which the forward advance is replaced, it shall replace the product on which the forward advance is to be carried out.

Paragraph 2. A previously used income may be converted to another income provided that it is justified in the circumstances of the company or association etc., such as the season, industry change, staff series, new business relations ; or group affiliation. The transfer of revenue can only be achieved if all income periods come to taxation, and if no income is in accordance with the rules laid down in paragraph 1. ONE, SIX. and 7. pkt., neither skipped or duplicated. The company or the association and so on shall, before the end of the income that is requested, notify the customs and tax administration. The customs and tax administration may permit the reorganization of a previously used income based on other aspects of the company or association, etc., must be submitted before the end of the income that is requested.

Paragraph 3. If a person, company, association, etc., or a circle of persons, companies and associations, etc. as a result of the stockholding, the Staff Regulations, Agreement or Joint Management shall exercise a dominant influence on a company or association etc., customs and tax administration may, with this influence, have a significant interest in the operational performance of this company or of this association, require that the company or association, etc., replaces its income so that it becomes : coincides with the one used by persons, companies or associations, etc. The determination of the share ownership is always available if a person, an association, etc., or a circle of persons, companies and associations, etc. as a result of ownership or availability of voting rights directly or indirectly, More than 50%. of the stock capital or at its disposal more than 50%. of the voices in the company.

Paragraph 4. In the case of income conversion, a income period shorter or longer than 12 months shall be carried out on the basis of income in the income term used.

Paragraph 5. All companies in a co-taxation benefit covered by § 31 or § 31 A must have the same income as the management company, cf. Section 31 (1). 6, or Section 31 A (1). 4. If a company at the establishment of the group has an income that differs from the revenue of the administration company, the income of the company shall be repaid in accordance with the rules laid down in paragraph 1. 1-4, so it expires at the same time as the management company's income. If the management company at the establishment of the group connection with another company has started an income that has not been started for the company concerned, the income concerned shall be deemed to have expired at the time of the date ; the establishment of the group connection. However, if a newly established company will establish a group connection with another undertaking during its initial income period and this income period concerns an income that has not yet been initiated by the other company, then the same tax shall not be included in the same time as the date of income ; for the first income of the newly-founded corporate income. If a carrier with an imprest incoming income is dissolved, section 5 (5) shall be replaced by the third paragraph. 2, similar application.

§ 11. If a company or association

1) are covered by Section 1 (1). 1, no. 1-2 b, 2-d-2, 3-5 (b),

2) is in debt to legal persons, as mentioned in Article 2 (2) of the body of the body. 1, (controlled debt) and

3) the foreign capital of the company or association (debt) in relation to the company ' s own funds at the end of the income year exceeds the ratio of 4:1,

the rate of interest and the rate of exchange which relates to the excess part of the controlled debt may not be deducsed. Debt to natural persons who are members of companies and associations, etc., covered by Section 2 (2) of the body of the body. ONE, TWO. Act. (Transparent units) shall not be regarded as controlled debt. However, the loss of liquids in exchange regains on the same loans in subsequent incomes may be dedutire;. The loans from third parties, which shall be deemed to have been secured by the controlling owner, directly or indirectly, shall be deemed to be subject to a controlled amount. The tax deduction shall be removed from the extent that the company or the association can demonstrate that similar financing can be achieved between independent parties. Fraction pruning shall be provided only if the controlled debt exceeds 10 million. DKK The deduction shall also be carried out solely on the part of the controlled debt, which would be re-qualified for own funds so that the relationship between foreign capital (debt) and own funds at the end of the income year shall be 4:1. Where there is a group internal control debt and a controlled debt to a third party, the deduction shall be carried out only for the corporate debt and then the controlled debt to third parties. The deduction shall be carried out only for Danish controlled debts and then for foreign controlled debts. No deduction shall be made for amounts which may be taxed in this country in accordance with section 2 (2). Paragraph 1 (d).

Paragraph 2. They are in accordance with the rules in paragraph 1 (1) 1, no. 3 a, taxable use associations may deductim from the taxable income from dividends, payment or bonuses granted to the members of the financial year in question. It is a condition for doing so that Members are not tax-free of the dividend and so on in accordance with Article 16 A (4) of the equation. 4, no. It is also a condition for doing so that the dividend and so forth shall be definitively fixed by the Union's Association at the latest six months after the beginning of the financial year. If the dividend and so forth shall be increased after the expiry of this period, the amount by which the dividend for the financial year in question shall be increased shall not be deduct from the deduct of the taxable income for the income concerned. The increase cannot be reduced to income from the income statement for future incomes.

Paragraph 3. The people in paragraph 3. 2 restrictions on access to deduction for divisive and other countries shall not include any discount benefits.

§ 11 A. Insurance premiums from a company or association etc., which is not an insurance company, to a group-related company, etc., cf. The section 2 of the body of the body cannot be deducible in the taxable income unless the insurance undertaking does not insignificantly draw similar assurances to independent parties. Insurance premiums paid to an independent insurance undertaking shall be deemed to have been covered by 1. pkton, to the extent that the risk is resecured from a company and so on which the group is concerned, cf. the section 2 of the body of the law, with the company and so on which pay the premiums. No matter what. and 2. Act. premiums may be deducted from the extent to which it is satisfied that the risk is reassured from an independent company or association etc.

Paragraph 2. The insurance premiums for the insurance undertaking shall not be included in its taxable income, the extent to which the group company has not paid the premium payments under paragraph 1. 1. No deduction may be made on the provision of provisions or reinsurance companies in companies relating to insurance, to the extent that the premium payments are covered by 1. Act. Payments shall not be deductible for insurance payments due to a corporation affiliation, and payments shall not be included in the calculation of the taxable income of the recipient company, to the extent that the right of deduction has not been deductible ; the premium payments referred to in paragraph 1. 1.

SECTION 11 B. In the calculation of the taxable income for companies covered by Section 1 (1), 1, no. 1-2 b, 2-d-2, 3 a-6, section 2, section 2. Paraguation 1 (a) and (b) or the section 21 (b) of the hydrocarbon tax. 4, the net income year net financing costs may be deduced only to the extent that they do not exceed the tax value of the company ' s assets multiplied by the standard boy, cf. paragraph 2. The cut-off may limit the deductible net income year of the income year of the income year to a sum of EUR 21.3 million. DKK However, no deduction shall be made to the extent that net financing costs are made up of net amount of net amount receivable, which exceeds income year ' s interest income, cf. paragraph 4. Such net mass losses shall be carried out to offset in taxable net gains on claims and interest income in subsequent income accounts of the net financing costs. The decisions after 3. and 4. Act. shall be drawn up together for cotaxed companies, cf. paragraph 8. If net financing costs are deductible, net loss of debt and financial contracts shall be considered to be subject to the cut-rate profit of the course for the prenatal first.

Paragraph 2. The default value of 1 year is calculated on the basis of a simple average of the discarded cashier credit for non-financial companies in July, August and September on the basis of a simple average of the non-financial companies of the months of July, August and September in advance of the year corresponding to the calendar year in the months. The monthly discharges of the monthly discharges of non-financial undertakings shall be made in accordance with the provisions of the European Central Bank (EC) No 2020/20. 63/2002 of 20. December 2001 concerning statistics on the interest of the financial institutions, on the loans from and lending to households and non-financial companies (ECB/2001/18). The monthly discarded monthly rate of discharges on non-financial undertakings is calculated as a weighted average of the effective interest rate for the outstanding loan mass, with two decimal places. The simple average, cf. 1. pkt., shall be done with one decimal place. The default number shall be published at the latest by 15. December preceding it for the year of the income corresponding to the calendar year.

Paragraph 3. The amount referred to in paragraph 1 shall be reduced to the amount referred to in paragraph 1 in the case of the company. 1 with the part to which the accounting value of its own assets associated with tonnage tax rederivatives account for the total accounting value of their own assets.

Paragraph 4. The net financing costs of the company shall consist of any negative sum of the following revenue and expenditure :

1) Taxable interest income and deductible interest expenses. However, the revenue from the goods debtors and other items of interest to goods creditors and other items of interest shall not be included.

2) Provision and lignments, which are deductible from the section 8 of the body of the body. 3, and similar taxable commissions and so forth, etc. for the stock debt and so on or other commodiments and so on shall not be included.

3) Taxable gains and deductible losses of debts, debts and financial contracts covered by the exchange rate applicable law. Gains and losses on goods creditors and items debtors shall not be included. Loss and benefits of loans shall not be included when the taxable exercise is based on the purchase and sale of claims or operating nutritional activities in the case of non-corporate contra-related, cf. Section 31 C. Loss and gain on bonds issued to finance the loan included in 3. Act. and financial contracts associated with it shall not be included. Gains and losses on contracts (term contracts etc.) serving to ensure operating income and operating costs, including in tax-based companies, are not included. Unrealized exchange gains on an interest rate on loan-based loans shall not be included, but may be produced by subsequent income years of net financing costs for offsetting in unrealized exchange rate on the same contract and in the same contract shall be implemented in the same contract that is realized in the income that the contract expires. However, the fees and losses on terminates, etc. shall be considered where the taxable person is susuing and selling claims and financial contracts, the nutritional business of finance, or if the co-contractor is the group-related, cf. § 31 C.

4) A calculated financing cost of financial leasing payments is taken into leased leases while lease includes a calculated financing revenue.

5) Taxable profits and utilised losses by the loss of shares, etc., covered by the tax burden of shares and taxable yields and taxable abstentions covered by the section 16 B. Is the sum of 1. Act. negative, it is not included, but shall be provided for offsetting in subsequent revenue. 1. Act. does not cover the return of the nutritional assets referred to in paragraph 1. FIVE, SEVEN. Act.

6) No matter No. 1-5 shall include revenue from revenue and expenditure resulting from CFC taxation in section 32 or as a result of retaxation after paragraph 15 (1). 8 and 9, in the Law No 426 of 6. June 2005, not in the net declaration of net financing costs.

Paragraph 5. The tax value of the company ' s assets shall be made up by the end of the income year. Depreciation-entitled assets are part of the written value. Assets that are not depreciable are included in the purchase of the acquisition sum for improvements to be made. Stock and so on subject to the issue of the shareholdings tax law, cf. however, paragraph 1 6, claims and financial contracts covered by the exchange rate law, and premium bonds and cash contracts shall not be included in the inventory of the company ' s assets. For assets, the net value of work in progress is calculated for foreign expense. The value of ongoing work, nutritional assets, stock-reptigators, and debts purchased by the sale of goods and other nutritional assets and services (items debtors etc.) are part of the asset inventory, to the extent by which the value exceeds the value of debt the purchase of goods and other nutritional assets and services (goods creditors, etc.). In-alone storage-taxed nutritional assets are counted. In the case of assets, the purchase order is included on the contract contract, etc., which serves to ensure operational income and operating costs, cf. paragraph 4, no. THREE, SIX. and 7. Act. When the company ' s assets are charged, the right of the undertaking shall be taken into account in accordance with section 12. The deficits that would be the cause of the resulting increase in income year without the deduction of income tax shall be included in accordance with paragraph 1. 1 and section C. A company ' s assets shall be included in the accounting value of financially leased assets of the leasing. The lease holder does not include financial unleashed assets. In the financial leasing between co-tax companies, cf. Section 31 or § 31 A, the tax value instead of the accounting value shall be used. Assets which are subject to taxation after the tax code of the tax is not included. Assets that have been inferred by foreign congleners, cf. Section 31 C is only taken into account to the extent that the assets remain in the company for at least two years. However, the assets are always included if the group has opted for international intertax according to section 31 A.

Paragraph 6. To the tax value of the company ' s assets in accordance with paragraph 1. Five is counted 20%. pro anno, cf. however, paragraph 1 12, of a total balance of the purchase price of the company ' s directly owned shares in affiliated companies, cf. Section 31 C, which is not part of the tax. In the case of co-tax companies, a total balance shall be conducted at the administration company. The purchase price of shares acquired from a group-related company, cf. section 31 C, or at a capital increase in a group-related company, cf. Section 31 C, do not confer the balance, cf. Four. and 5. Act. To the extent that it can be documented that a capital increase in a direct-owned company has been provided for the purpose of indirect purchase of shares in a company outside the group, cf. Section 31 C is considered to be the sum of the purchase at the time of the indirect acquisition. A maximum of five times the amount of the deposited capital and the amount to be taken into account can be taken into account if the company was acquired directly by a company that is involved in the tax. The balance shall be reduced by :

1) The trading value of the stocks in Danish companies, fixed operating premises and real estate holdings in Denmark, owned directly or indirectly by the directly owned company.

2) The commercial value of the purchase price of the company, cash, transferable securities, etc., as defined in the light of the day of the purchase of the company. Article 34 (4) of the stock-tax system. 6. However, there must be consolidated consolidation with companies linked to subsidiaries, cf. § 31 C.

3) The value of subsequent direct or indirect acquisitions of shares in Danish companies, fixed operating places and real estate in Denmark.

4) The shares of the shares of the directly owned company and the company ' s direct or indirect ownership of the shares of affiliated companies, cf. Section 31 C, however, this shall not apply if the shares are allegedly held to a company or farm operating system. The shares of a group connected party to which companies or firm operating places directly or indirectly own shares are reduced by themselves, in so far as the direct and indirect ownership of the company is less in the business of the undertaking, than in the affluous company. The sum of the sum shall be deducted from the value of the direct or indirect ownership of the holdings in Danish companies, fixed operating premises and real estate in Denmark. Indirect abstention through the abstention of a co-taxed company or fixed operating site and the cessation of convalesce shall be treated as a commercial value.

5) The cost of the business in the direct company and company of the company directly or indirectly owned companies, cf. Section 31 C, allegedly the company of a corporation affiliated company which, directly or indirectly, owns shares in the company, shall be reduced by itself, in so far as the direct and indirect ownership share is less in it ; transferable companion than in the affluous company. The abstention of the company shall be deducted from the value of the company ' s direct or indirect ownership shares in Danish companies, fixed operating premises and real estate in Denmark.

6) Extractions from the direct-owned company to co-taxation companies and fixed operating establishments which exceed the cash and abstentions which have decreased the balance of the balance. 2, 4 and 5.

7) Proposals of profit preferences in the directly owned company or companies in which this company directly or indirectly owns shares, to corporate companies, cf. Section 31 C, which is not included in the tax system, to the extent that the co-taxed companies and fixed operating sites have a small direct or indirect ownership in the undertaking ' s undertaking other than in the encoding company.

8) Deposits from the directly owned company or companies in which this company directly or indirectly owns shares, to companies and fixed operating establishments that are included in the tax and to group-related companies, cf. Section 31 C, which is not included in the tax system, to the extent that the tax collective companies and fixed operating sites have a small direct and indirect ownership in the beneficiary company than in the grant company.

Paragraph 7. If a company is not taxed throughout the income year, assets shall be taken into account in the calculation provided for in paragraph 1. 5 and 6 in relation to the amount of the tax period for which a calendar year is to be used. The amount referred to in paragraph 1. 1, cf. paragraph 3, adjusted accordingly.

Paragraph 8. Companies forming part of a tax after Section 31 or Section 31 A shall make the net financing costs of the group and the fiscal value of the assets collected. The amount referred to in paragraph 1. Paragraph 1 shall apply collectively to the co-taxed companies. Inserts the tonnage-tax company in a collection of taxation in accordance with the same amount of taxation. section 31 and 31 A, consider paragraph 1. 3 total use of the co-taxed undertakings and the loss of shares in tax collectively and debts and claims between the tax-based companies. If a company is not included in the taxation of the entire income year, the decision shall be taken into account in the calculation of 1. Act. the company ' s assets at the end of the part-period, cf. Section 31 (1). 5, in relation to the number part part of the part-period of a calendar year. Where deduction is carried out in accordance with paragraph 1, 1, the pruning shall be prorated in the light of the net contribution of the net financial expenditure of each company without net loss uncut in accordance with paragraph 1. ONE, THREE. pkt., exceeds the tax value of the company ' s assets, cf. paragraph Five, multiplied by the standard boy.

Niner. 9. Fraction pruning from paragraph 1-8 shall be carried out after a deduction of deduction after Article 11.

Paragraph 10. If a company in an income is deduced in accordance with paragraph 1, 1, cut net losses in debt and financial contracts covered by the exchange rate applicable law could be deducised in exchange rates on debt and financial contracts covered by the exchange rate law of the three subsequent incomes. No matter what. Act. may cut unrealized losses of the liquids in an interest rate of a loan with security under the contract of the contract to deductible exchange regains from the same contract and in the same contract that is realised in the same contract ; the income in which the contract expiates. In the course of the transmission of the Kurds, the elders shall be resisticounted first. Courier shall be gathered together for co-tax companies at the management company. In the case of termination of termination of the management company, the pre-eligible classes shall be apportionated according to the tax value of the assets, cf. paragraph 5 and 6, in the receiving companies. No matter 4. Act. may be cut in the event of an unrealized rate of coups at a rate of interest in the company which has entered into the interest rate, provided that the company in question is replaced by the same tax.

Paragraph 11. Paragraph 1-10 does not include life assurance undertakings. Life insurance companies may, as an administration company, in a co-taxation system, may have described cures, cf. paragraph Ten, the cut of the locusts can not be resided in the life assurance profits of the life-insurance company.

Nock. 12. For the purposes of paragraph 1. SIX, ONE. pkt., used the co-conversion percentages listed in the second-9. Act. For the income of 2010, the percentage is 17.5. For the income of the year 2011, the percentage is 15. For the income of the year 2012, the percentage is 12.5%. For the income of the year 2013, the percentage is 10. For the income of the year 2014, the percentage is 7.5%. For the income of the year 2015, the percentage is 5. For the income of the year 2016, the percentage is 2.5. For the income of 2017 and later revenue, the percentage is 0.

§ 11 C. The taxable income before a net financing cost, cf. Section 11 B, paragraph 1. 4, for companies covered by Section 1 (1). 1, no. 1-2 b, 2-d-2, 3 a-6, section 2, section 2. Paraguation 1 (a) and (b) or the section 21 (b) of the hydrocarbon tax. 4, may be reduced by 80%. as a result of the net financial expenditure following possible deduction of deduction from section B. The taxable income and net financial expenditure shall be adjusted for net losses which are not cut in accordance with section 11 B (3). ONE, THREE. Act. The cut-off may reduce the deduction of the income year of the income year of the income year in accordance with section 11 B (3). 1, cf. Section 11 B, paragraph 1. 3 and paragraph 1. SEVEN, TWO. Act. If the taxable income is less than net financing costs, the deductible net financing costs may not exceed the amount in 3. Act. Trim net financing charges after 1. 4. Act. may be transferred to deductions in subsequent incomes. Completed net financing charges are included in the calculation after 1. Act. in subsequent incomes.

Paragraph 2. Companies forming part of a tax after Section 31 or § 31 A shall make up to the taxable income and net financing charges as a whole. Amount in section 11 B, paragraph 1. Paragraph 1 shall apply collectively to the co-taxed companies. Where deduction is carried out, the deductible net financing costs of the companies shall be reduced proportionately to the extent to which the net financing expenditure of each company exceeds 80%. of the company ' s taxable income before a net financing cost. If the deduction allocated by the allocated deduction exceeds net financing costs in individual companies, the excess deduction pruning shall be apportionated. Funding costs shall be combined for the co-tax companies at the management company. In the case of termination of termination of the management company, the pre-eligible financial expenditure shall be apporised according to the tax value of the receiving companies.

Paragraph 3. Paragk 1 and 2 do not include life assurance undertakings. Life insurance companies can, as an administration company, in a co-taxation system, make net financial costs cut. The cut net financing costs may not be resided in the life assurance undertaking ' s income.

§ 12. If the taxable income is deficit, this deficit may be deduculent by the deducisation of the taxable income for the following income in accordance with the rules laid down in paragraph 1. Two and three.

Paragraph 2. Deposits from previous income can be deduculent in that part of the year's tax-taxable income, which does not exceed a 7.5 million base amount. DKK (in the 2010 level). A remaining deficit can be deducred from 60%. of the amount of the year of the year, which exceeds the amount of the year. The basis of 1. Act. regulated by a person ' s tax on 20.

Paragraph 3. Deposits may only be supplied to deduction in a later income, to the extent that it shall not be applied in accordance with the rules laid down in paragraph 1. 2 can be sprumbled in previous years of income.

Paragraph 4. If a company and so on chooses to apply the rules in section 31, paragraph 1. 9, or equal to section 33 H (s) of the body. 1, and this choice shall mean that the income of the taxable income in the income year represents a greater amount than the taxable income in the income year calculated in accordance with the rule set out in paragraph 1. 2, find the rule in paragraph 1. 2 shall not apply to the income concerned.

§ 12 A. When a company and so on in an income is a compulsion in a reenactment, the resulting deficit shall be reduced and then unexploited deductible losses resulting from the rules of section 9 (4) of the asset ' s liability. 4, and section 43 (3). 3, the Danish exchange rate law, section 31 (1), 3, and section 31 A (1). 3, and the property section 6 (6) of the property. 3, from that and previous income, with the amount by which the debt has been reduced, cf. however, paragraph 1 2. The reduction takes effect on the income in which the reconstruction proposal is upheld, and for subsequent incomes.

Paragraph 2. The amount of the reduction in accordance with paragraph 1 is reduced :

1) With that part of the Occupation Amount, which is tax duty for the debtor company.

2) With the part of the debtor ' s income, which originate from the company ' s release for debt obligations, which constitute tax-free yield after paragraph 13 (1). 1, no. 2, or tax-free supplements after Section 31 D.

3) To the extent that the debtor ' s debtor ' s debtor ' s debtor ' s debtor ' s debtor ' s debit ' s debt, sections 8 and 24 A shall not include the profit on the income of

Paragraph 3. A total or partial conversion of debt to shares or convertible bonds is equable to a debt reduction. In these cases, the amount of the deficit shall be reduced by the amount of the converted claim exceeding the converted claim value at the time of conversion.

§ 12 B. Section 12 A shall apply by analoging to contracts for a total arrangement between a debtor company and its creditors on the suspension or reduction of the company ' s debt (optional chord).

§ 12 C. Section 12 A shall apply mutatis muth to the extent to which a reduction or the introduction of a claim shall be made in the case of a grant after paragraph 31 or of a capital deposits to the debtor or to a company and so on which the debtor owns more than 10 ; Pct. in the case of the stock or the capital chapter, when the capital injection is directly or indirectly carried out :

1) By creditor of the claim or creditor ' s spouse.

2) By a company in which the creditor or creditor ' s spouse directly or indirectly owns more than 50%. in the case of shares of shares or of the capital chapter, or directly or indirectly, of 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 capital capital of the creditor or at its disposal more than 50%. 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., that have it in paragraph 1. 1-4 related ties to the guarantor.

6) For a previous creditor or a guarantor for the claim and by persons and companies that 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 where the reduction or entry is equivalent to a total arrangement between the debtor and its creditors. If the capital intake is made in the acquisition of shares or convertible bonds in the debtor company, section 12 A, paragraph 1 shall be found. 3, corresponding use.

Paragraph 3. Where the amount of the reduction shall be disclosed from the amount of grants or capital intake.

Paragraph 4. The amount of the reduction in accordance with paragraph 3 is reduced :

1) With that part of the Occupation Amount, which is tax duty for the debtor company.

2) To the extent that the debtor ' s debtor ' s debtor ' s debtor ' s debit ' s book of section 8 at the time of the date of application or the imposition of the claim or the creditor, the guarantor would have been obtained by a guarantee payment, not to include a payment ; any gains on the claim or the repayment of the taxable income statement.

Paragraph 5. The amount of the reduction in the amount of the reduction in accordance with paragraph 1. 4, no. 2, shall be dissurized as the difference between the creditor ' s acquisition sum for the amount receivable or the purchase price of the creditor, the guarantor would have a possible guarantee payment for that claim, and on the other side of the claim at the time of entry, taking part from the resulting capital intake.

§ 12 D. If more than 50%. of the share capital of a company or the other in a society covered by Section 1 (1). 1, no. 1, 2 or 4, or § 2 (2). Paragraph 1 (a), or a similar company, etc. covered by Section 2 A (1). 1, at the end of the income year, other shareholders or participants may be owned by other shareholders or participants than at the beginning of an earlier income in which the tax income shown in the taxable income cannot be reduced by reducing the taxable income to an amount less than the positive net income of the company, cf. paragraph 3, with the addition of the income from the depreciation of depreciation-justified operating methods and ships. Similarly, if other shareholders or participants at the end of the income year end than at the beginning of the deficit year, more than 50% shall be available. of the overall voting value.

Paragraph 2. In the case of amendment of the owner-circle referred to in paragraph 1. ONE, ONE. a point or change to the voting value as referred to in paragraph 1. ONE, TWO. pkt; the deficit may not further reduce the taxable income if the company or association at the time of change in ownership of capital or shares or to change the raw material value in the essential part of the vote shall not be reduced ; the economic risk of professional activity or by commercial activity in one or more subsidiaries in which the company owns at least 25%. Of the stock record. 1. Act. however, do not apply if the company or association of the Foundation and until the time of change in ownership of shares or shares or to change the raw material over the voting value does not have a business enterprise.

Paragraph 3. Nettokapital revenues shall be calculated as the sum of :

1) interest income and interest rate expenditure and deductible from the section 6 of the body of the body ;

2) taxable gains and deductible losses after the exchange rate law,

3) yield from section 16 A of the body of the body,

4) taxable gains or deductible losses in respect of the shares of shares of shares of shares of the shares of the law and the body of the body of the body of the body of the body of the body of the body of the body

5) the section 8 (5) of the body of the body of the body 3, commissions, etc.

Paragraph 4. Paragraph 1-3 shall not apply :

1) on undertakings whose shares are engaged in trade in a regulated market, or

2) if the one in paragraph 1 : 1 that change in the ownership of the company shall be attributed to the transfer of capital units and so on to persons referred to in Section 1 (1) of the penalty slots. 2 (a-f, a spouse, parent ' s offspring or stepparents.

Paragraph 5. If a company or association is covered by paragraph 1 (1). 1, no. 1, 2 or 4, or § 2 (2). Paragraph 1 (a), or a similar company, etc. covered by Section 2 A (1). 1, owns 25%. or more (the parent company or parent association) of the shares of another company (subsidiary) or part of another association (subsidiary) is not considered the parent undertaking or the parent association, but the shareholders of the parent undertaking ; or the participants in the mother association in the application of paragraph 1. 1 and 2 in order to own the shares of the subsidiary or the shares of the subsidiary society after their proportionate share of the parent undertaking ' s share of the parent undertaking or by the share of the parent association.

Paragraph 6. Paragraph 5 shall not apply to parent undertakings whose shares are engaged in trade in a regulated market. A parent company whose shares have been admitted to trade in a regulated market between the beginning of the deficit wound and the closure of the income in which the deficit is being deducted may, with future effect, choose to apply the rules set out in paragraph 1. 5 if the stock in the parent company is noted. If the stock in a parent company in the same period as mentioned in 2. Act. it ceades to be admitted to trade in a regulated market, this shall not be regarded as a change in the application of paragraph 1. 1 and 2, by a stock exchange, where a company's owner of a company is after 1. Act. shifting from shareholders of a company whose shares are not available for trading in a regulated market, for a company whose shares are available for trade in a regulated market, the latter may choose to apply the rules set out in paragraph 1. 5 if the shares have been noted. Paraguation 5 shall apply mutatis mutable to parent undertakings whose shares are not available for trade in a regulated market and a parent associations located in a State with which Denmark has entered a double tax agreement, Greenland or The Faroe Islands or in a country within the European Union. However, this only applies if the owner shares of the subsidiary between the start of the deficit year and the end of the income in which the deficit is being deducted is transferred to either the parent company after 5. Act. or another subsidiary in which the parent undertaking in the said period owns at least 25%. of ownershares. 5. and 6. Act. shall apply mutatis mutable to associations. If a parent undertaking or a moderation between the beginning of the deficit wound and the closure of the income in which the deficit is being deducted from the deficit, has reduced its ownership share to less than 25%. or raise its owner's share to 25%. or more, the rules shall apply in paragraph 1. 5 shall determine whether ownership change pursuant to paragraph 1 shall be made. One and two.

Paragraph 7. The limit of paragraph 1. ONE, ONE. points, which will not reduce the taxable income to a sum less than the positive net income of the company, shall not apply to losses arising from income, in which the company in the entire income year ran business as a the financial institution, the insurance undertaking, the investment organization or the real credit institution or, by the way, fuelled by buying and selling receipts or running nutritional activities by financing.

§ 13. The taxable income is not included :

1) An overheading that a company achieves in the issue of shares or extending its share capital.

2) Exchange, as in section 1 (1). 1, no. 1-2 b, 2-d-2 (2), 3 a-5 b, mentioned companies and associations, etc., of shares or shares in companies covered by paragraph 1 (2). 1, no. 1-2 b, 2-d-2 j and 3 a-5 b, or companies belonging abroad. However, this is only applicable to yields of subsidiary assets and corporate assets, cf. Asset Taxation Act, section 4 A and 4 B. Determination in 1. Act. shall not include yields where the profit-making company has deductible the yield of the yield, unless the tax on foreign charges is dropped or reduced in accordance with the provisions of Directive 2011 /96/EU on a common taxation system for mother-and subsidiaries from different Member States. The provision in 1. Act. nor does it include dividens, to the extent a subsidiary of a lower owner-level has had deductible deduction of the yield without the deduction of the deduction of the yield to an intermediate level, and the source of taxation of the profit or the amount of the profit from the tax on the yield, the dividends in none of the intermediate levels shall be waived or reduced in accordance with Directive 2011 /96/EU. The provision in 1. Act. does not include the yield on shares as referred to in Article 19 of the Asset Taxation Act. The provision in 1. Act. the corresponding use shall apply where the beneficiary is a corresponding company or association, etc., as referred to in section 2 (2). 1 (a) and the company or association, etc. are indigenous to a Member State of the European Union or of the EEA, on the Faroe Islands or in Greenland or a State which has a double-taxation agreement with Denmark. In the assessment of the presence of a company or association, etc., as referred to in section 2 (2). 1 (a) satisfies the condition of 2. PC shall be taken into account in the profit-making undertaking of the company or association, as well as the association or association.

3) Amouns referred to in the country where they are based, cf. Section 1 (1). 1, no. 1, 2, 2, e, 2 f and 2 h, bearing in the interest of the shares of your own shares or shares. The provision shall apply by analoging the equivalent, if the beneficiary is a similar company or association, etc. as referred to in section 2 (2). 1 (a) and the company or association, etc. are indigenous to a Member State of the European Union or the EEA, on the Faroe Islands, in Greenland or a State which has a double tax agreement with Denmark.

4) Amouns paid to an employee investment company, cf. Section 1 (1). 1, no. 2 b, employee attendees.

Paragraph 2. Exchanging tax-free portfolio management as referred to in Article 4 (c) of the Asset Taxation Act is not covered by paragraph 1. 1, no. Articles 2 or 3 shall be received by companies and so on which are taxable in accordance with sections 1 or 2 (2). Paragraph 1 (a) shall be taken into account in the calculation of the income of the taxable income by 70%. of the amount of the yield, cf. Two. and 3. Act. 1. Act. shall not apply where the shares of the profit-making company are covered by section 17 or 19 of the asset tax on the shares of shares. 1. Act. shall not apply where the profit-making company has deductible from the profit. Paragraph 1, no. TWO, FOUR. Act. shall apply by analog;

Paragraph 3. Insurance undertakings may, in the calculation of the taxable income, in accordance with the rules laid down in paragraph 1. 4-10 or § 13 F deduction amounts taken to tax after retirement tax law, 8, to the extent that the income tax of the income tax of Article 8 has reduced the income of the income of the income year or benefits to the insured persons ; on the income corresponding to the income year following that law, and amounts drawn up to cover commitments to the insured persons in the form of technical provisions and statutory levelling reserves in the field of credit, and bail insurance.

Paragraph 4. Trade and equity and property rights which should not be included in an insurance undertaking or to a tax-free subsidiary income tax, and then yields tax exempt after a double tax agreement is considered to be considered as : maximum extent possible for the amount of payments made to the insured of the holders referred to in paragraph 1. THREE, ONE. the provisions referred to in paragraph 8, and to tax on the basis of the provisions of Article 8 of the Pension of Pensions Act, before these amounts are deducted from the income of the taxable income. Trade and profit margins for shares in the co-taxation involved subsidiaries and their own shares shall not be included in the insurance undertaking, the parent undertaking, account of the abovementioned yields and axes. For the income in which shares or property is sold, the sum of yields and avenues shall be reduced as set up in accordance with 1. and 2. Act. with a taxable profit at sales. The sum of yields and avans, as done after 1. and 2. Act. be attributed to deductible losses on the sale of shares or property of the income in which the loss is used for offsetting. A company's untapped deductible losses at the end of the last income in which yields and promotions in the company concerned may reduce the deduction of the insurance undertaking by the insurance undertaking by the insurance undertaking, the sum of which is the sum of : yields and avant-garments after 1. and 2. Act. for the following revenue. 4. and 5. Act. However, only the extent that the loss has affected the sum of yields and avant-in advance shall be applied in accordance with 1. and 2. Act. in the insurance company in previous revenue. If not all shares of a tax-subsidiary company are directly or indirectly owned by the insurance undertaking, the proportion of the tax free and the eligible yields and axes of the subsidiary undertaking shall be included in the subsidiary undertaking corresponding to the insurance undertaking, average ownership of the subsidiary equity of the subsidiary in the income year.

Paragraph 5. For non-life insurance undertakings, the reduction in the right of deduction shall be made in accordance with paragraph 1. However, 4 not more than that part of the tax free and the free yields and avant-garde, etc. corresponding to the amount by which the company's payments to the insured, the products referred to in paragraph 1, shall be equal to the amount of the undertaking. THREE, ONE. ................ by the insurance technique for its own account. The decision after 1. Act. by the year to the year, an account shall be taken of the total tax free of the undertaking and the free-income eligible yields and tax-free avans and a balance sheet total (GL account) and an account of the amount with which the company ' s payments to the insured are to be taken ; the referred to in paragraph 1 THREE, ONE. ................ of the insurance technique for its own account (operating account). If the balance of the operating account is positive and there at the same time a positive balance of the GL account is used, the minimum of the two amounts shall be used in 1. Act. The balance of both accounts is reduced by the amount of the amount used in 1. pkton, after which the remaining balances are transferred to the following revenue.

Paragraph 6. Where an insurance undertaking is subject to tax with another insurance undertaking, a total account shall be taken of tax-free and imputed yields and more avant-garde, etc., 4. The amount of the split split is prorated between the insurance undertakings, and deduction shall be carried out in accordance with paragraph 1. 4 respectively. 5. The total aggregation of each of its aggregation shall be made after 1. and 2. Act. for life assurance undertakings and non-life insurance undertakings. The insurance companies which, in the case of a proportionate distribution, take advantage of another insurance loss, shall reimburseth the latter company the fiscal value of the loss. The compensation does not have fiscal consequences for the companies. Where a life insurance undertaking is directly or indirectly the owner of a non-insurance company to which it is subject, tax-free and free yields and axes, etc. that will not be considered to be included in the Damaged Insurance Company payments to the insured and to the holders referred to in paragraph 1. THREE, ONE. ..................

Paragraph 7. If an insurance undertaking in the entire income year directly or indirectly owns 25%. or more of one or more companies which are not covered by taxation, the insurance undertaking, the parent undertaking, shall be involved in the application of the rules laid down in paragraph 1. 4 and 5 together with tax-free and impusive yields and avans in the subsidiaries. From its subsidiaries, the portion of the tax-free and leviated yields and avenues corresponding to the average share of the subsidiary holdings of the subsidiary in the income year shall be counted on from its subsidiaries. Trade and axes concerning the parent company ' s shares in the subsidiary undertakings shall not be included. To that extent, tax-free and fair yields and adolescs in subsidiaries which are insurance undertakings, in accordance with paragraph 1. 4 and 5 are considered coiled for payments to the insured to the aid referred to in paragraph 1. THREE, ONE. ... (b). (b). (b). (b). (b). (b) (b) (b) (b) (b) (b) (b) (b) (b) The provisions and 2. Act. In the case of flat-rate operations abroad, which operate an insurance undertaking and which are not covered by international taxation, 4. Act. equivalent use.

Paragraph 8. If the sum of yields and avans shall be discharged in accordance with paragraph 1. 4, 6 and 7 for a life assurance undertaking more than payments, provisions and tax on the section 8 of the Pension of Pensions Act as referred to in paragraph 1. FOUR, ONE. complicating, the excess amount for the taxable income of the company shall be included. If the sum is negative for the life assurance undertaking, the amount shall be deducivited by the deduction of the taxable income of the company. The deduction shall be carried out before any unused deficit in respect of previous revenue and cannot make its taxable income negative ; any remaining negative sum shall be deducted from yields and avant-garde, as appropriate ; paragraph 4, 6 and 7 for subsequent incomes. In the case of derogation from taxation after Section 3, the company may be paid the tax value calculated with the tax value in section 17 (3). 1, the percentage of any remaining negative sum after 4. Act. in relation to the last income, where the company is tax duty. The amount paid shall not be taxable. 5. and 6. Act. it shall apply mutatis muted to life assurance undertakings for the income where the company receives the life assurance population under administration under section 253-258 in the Act of Financial Act, in that a remaining negative sum after 4. Act. However, untapped deductible losses, which have affected the sum of the sum of the amount of the income or property sold, have been attributed to the sum of deductible losses. These unused losses may subsequently not be used in accordance with the rules of the tax law or the property tax law of the shareholdings of the market.

Niner. 9. Stock and Real Estate Enforts, which are included in payments to the insured, for provisions pursuant to paragraph 1. THREE, ONE. pkton, and to the tax on the section 8 of the Pension of Pension Act, and the provisions referred to in paragraph 1. 4 said avancer shall be dissolved as the difference between the value of the income year and the value of the beginning of the income year (the stock principle). In the case of purchases and sales in the course of the income year, the acquisition sum and the sum total of the stock and real estate holdings shall be included in the calculation of stock and property rights as referred to in 1. Act.

Paragraph 10. The inventory shall be carried out in accordance with paragraph 1. 4-9 are treated shares of shares which are carried out through an account-leading unit of investment, as well as activances that are being raised directly.

§ 13 A. The institutions authorised as a real credit institution, having been granted a financial undertaking, shall not include the contribution of borrowers to a residual debt adjustment fund, as provided for in the financial undertaking. section 23 g (g), 1, in the notice. 571 of 15. 1 August 1989 of the Law on Realtor and Section 4 (b) of the notice No 699 of 5. November 1987 of the Act of Finance for Agriculture, and so on, as amended by law no. 373 of 6. July 1988. The institution and so on shall not include the yield of the Fund's funds either.

§ 13 B. Pension institutes must not include income tax return on account of pool deposits and taxed in accordance with pension tax law, or amounts which are subject to Section 30 A of the Pension Act of Pension will be transferred from deposits to the equalisation of negative pulp return. Pension institutions cannot deduction from attribution to the income of pension funds to the loan accounts of the pension funds.

Paragraph 2. Determination of assets in pools in a financial institution which is transferred to cover administration costs etc. shall be taken into account in the calculation of the taxable income of the financial institution.

§ 13 C. Guarantees made in the income years 1959-89 with effect on the inventory of the taxable income and as per the date of income. 31. In December 1994, the calculation of the taxable income of the insurance undertaking shall be taken into account in accordance with the rules set out in 2. -5. Act. For each 10 percentage point assurance undertaking technical provisions for own account, with the exception of bonus-level provisions, the end of the income year has been reduced in proportion to the technical provisions for their own account, other than those for the payment of : bonus-level provisions, per unit ; 31. In December 1994, 10% of the security fund claims is counted as a percentage. 31. In December 1994, the balance of the taxable income of the company on the income concerned is the income of the undertaking concerned. Reduces the safety fund provision in full or in part, including by transfer, shall be taken into account by a corresponding amount in the balance sheet of the company ' s taxable income for the income concerned. Security Fund reserve, counting on the income return decision pursuant to 3. provisions may be deducted from the statement of security funds which, for the relevant or subsequent income concerned, shall be taken into account in the income statement pursuant to 2. Act. Safety fund concerns that are not included in the income statement pursuant to 2. and 3. PC shall be taken into account in the calculation of the taxable income of the income in which the company ceaseless to operate an insurance undertaking.

Paragraph 2. On the transfer of insurance, like the 31. In December 1994, the provisions of Chapter 1 of the Pension Act and which have not been topical before 1. in July 1996, from a non-life insurance undertaking to a life assurance undertaking, paragraph 1 shall apply. ONE, THREE. intended, not applicable to a concurrent transfer of security funds to the life assurance undertaking ' s security fund. However, this does not apply to the transfer of security funds, corresponding to that part of the indemnification of the indemnities of the indemnification of the indemnification of the insurance company. 31. in December 1994, corresponding to the relationship between the insurance transferred and all assurances in the non-life insurance undertaking. 31. December 1994. In the transfer of a life assurance undertaking, it is also a condition that the safety fund for the life assurance undertaking and the provisions referred to in paragraph 1 shall be subject to the provisions of the life assurance undertaking. 1 per per 31. In December 1994, they shall be increased by the transfer of reassurances corresponding to the provisions and provisions. For the purposes of paragraph 1. 1 in the receiving company shall be considered to increase the need for a security fund as untaxed hencelisations.

Paragraph 3. In the case of a transfer of the items referred to in paragraph 1. whereas, in the case of reassurance, two assurances do not occur at the same time the transfer of all of the security funds which may be transferable in accordance with the same paragraph shall not include the non-transferable part of these provisions in their taxable age, income for the income in which the insurance is transferred.

§ 13 D. Energinet.dk and its subsidiaries each separate a separate taxable income for the activities covered by their separate accounts for electricity-related activities in accordance with section 12 of the Act on Energinet.dk.

Paragraph 2. Energinet.dk and the undertaking ' s subsidiaries shall each separate a separate taxable income for the other activities not covered by paragraph 1. 1.

Paragraph 3. Where a write-off asset is used in the case of activities covered by both paragraph 1. This does not include asset entries with entry values after Section 35 O.

§ 13 E. In the case of the co-taxation of Energinet.dk, the activities covered by Energinet.dk's and its subsidiaries ' electricity activities are considered to be a separate entity in relation to the others, in accordance with section 12 of Article 12. activities.

§ 13 F. Life insurance undertakings may make up the taxable return of a share in a legal person as the sum of the claims from the proportion and profit and loss of the proportion taken in accordance with paragraph 1. 2, cf. however, paragraph 1 3 and 4 when the legal person under Danish tax rules does not constitute an independent tax subject. It is a condition that, in the income of the income year, the taxable person shall not be associated with the legal person in accordance with the legal person. Section 5 of the Act of Financial Business. 1. and 2. Act. shall apply mutatis muctis, if the investment is to be made through an account-leading investment association, cf. Paragraph 2 of the Act on the taxation of members of account-leading investment associations.

Paragraph 2. Gains and losses of a proportion in a legal person referred to in paragraph 1. 1 shall be the difference between the value of the share at the end of the income year and the value of the beginning of the income year (storage principle). In the event of a purchase of the share in the income year, the benefits and losses shall be made as the difference between the value of the share at the end of the income year and the purchase price of the shares. In the income year, the proportion shall be paid and losses as the difference between the sum of the shares of the shares and the value of the cooperative value at the beginning of the year. If the proportion is acquired and passed in the same income, gain and loss as the difference between the andelesssum and purchase of purchase.

Paragraph 3. Tax deduction may be deducible from tax paid to foreign state, the Faroe Islands or Greenland, in accordance with Article 33 (3) of the body of the body. Paraguation 1 and 2 where the tax base is charged in accordance with paragraph 1. One condition is that tax-taxable tax shall make a tax deduction according to section 33 (3) of the body of the body. 1 and 2, for all income from the same country.

Paragraph 4. The taxable income provided for in paragraph 1. 1 shall be reduced by a proportionate part of the value increase in the legal person corresponding to the expenditure incurred by the taxable person, because they may be transferred to operations between the taxable and the legal entity ; Person. The taxable income provided for in paragraph 1. 1 shall be given a proportionate proportion of the fall in the value of the proportion of the legal person corresponding to the income of the taxable person, which is tax-free because they can be attributed to transactions between the taxable and the legal person. The taxable income provided for in paragraph 1. 1 shall be attributed to a proportionate part of the legal person's loss on claims on companies which are affiliated with the taxable person, cf. Section 4 (4) of the exchange rate law. 2.

Paragraph 5. Selects the taxable income of a share in a legal person in accordance with paragraph 1. 1, this choice shall be binding on the taxable, as long as the savings is placed in the share, cf. however, paragraph 1 ONE, TWO. Act. Is the condition in paragraph 1. ONE, TWO. in accordance with paragraph 1, the taxable person shall not be able to choose to comply with the provisions of the taxable person. 1.

Paragraph 6. When disposable of the immovable property acquired before 1. This January 1998 shall be taxed on the part of taxable profit or loss related to the period from the time of acquisition to the 1. In January 1998, according to the rules of the depreciation of the law and the tax on the property tax law. Depreciation carried out after the year 1997 shall be attributed to the taxable income in accordance with paragraph 1. 1.

Paragraph 7. At the disposal of the immovable property acquired on 1. In January 1998 or later, depreciation shall be attributed to the taxable income provided for in paragraph 1. 1.

Paragraph 8. Discover the taxable return of a share in a legal person in accordance with paragraph 1. Paragraph 13, paragraph 13, shall apply. 4-10, don't apply.

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

§ 13 H. Receiving a life assurance undertaking covered by Section 1 (1). 1, no. 1, at a concentration with a pension fund covered by section 3 (3). 1, no. 9, or with a labor-related life insurance company subject to section 3 (3). 1, no. Eighteen, self-capital of the pension fund or occupational life-insurance company, own funds shall not be counted in the calculation of the life assurance undertaking ' s tax-taxable income. 1. Act. shall apply by analogous to the concentration of a non-resident life insurance undertaking if the assets and liabilities etc. are linked to the firm operating premises of the company or the property of the company in this country.

Paragraph 2. The merger has fiscal effect from the cutting date of the opening balance of the receiving company drawn up in the concentration. The opening date of the receiving company ' s opening balance must be coincided with the date of the receiving company ' s financial year. § 8 A, paragraph 1 Paraguate 2 and 3 shall apply mutatis mutis. 1.

Paragraph 3. The equity capital referred to in paragraph 1. Paragraph 1 shall not be included in the calculation of the life assurance undertaking's taxable income, re-taxed in accordance with the rules of the second-4 basis. pkton, to the extent that the amount is not taxed according to section 13 C. ls the self-assurance of life assurance by the end of an income reduced to the own funds in the opening balance of the receiving company, cf. paragraph 1, the amount corresponding to the downward calculation of the taxable income of the company shall be subject to retaxing the total amount of the sellers received. The amount of the income of the income tax shall be as the amount of positive difference between own funds in the second year of the year. Act. the indicated opening balance, with deduction of retaxed amount and sellers ' own funds at the end of the income year. Received own funds that are not included in the income statement after 2. and 3. PC shall be taken into account when the income of the taxable income for the income in which the company ceamates the life assurance business. Where the undertaking ' s life assurance undertaking is in full or in part as part of a merger, fission or transfer of assets by the rules of the Merger Tax Act, it shall enter or the recipient companies in the retaxing obligation on the basis of the rules on which it is subject ; the share of the deposited company ' s own funds received. 5. Act. it shall apply only if the assets and liabilities etc. are to be assigned to a receiving party belonging to the country or any permanent farm or real estate of a resident company in this country or in the country of a resident company.

§ 13 I. A water supply company and so on which is subject to section 1 (1). 1, no. 2 h, or § 1, paragraph 1, no. 1, cf. Section 2 (2). Paragraph 1, in the organisation and economic situation of the water sector, and which, by means of a merger with a water supply company, etc. covered by Article 3 (3). 1, no. 4 a, receives the wealth of this water supply company, etc., may choose not to include the susceptible wealth received in the inventory of the income of the taxable income.

Paragraph 2. If the receiving water supply company, etc., shall be provided in accordance with paragraph 1. 1 has chosen to ensure that the assets received by the water supply company etc should not be taken into account in the calculation of the taxable income, the receiving water supply company, etc., is the entry values of the receiving party ; depreciation-entitled assets to 0 kr. The entry values for the assets and liabilities that are not covered by 1. pkt. shall be determined in accordance with the rules laid down in section 5 D (1). 8-10.

§ 14. For the sections referred to in section 1 (1). 1, no. Three, mentioned cooperatives, constitute the taxable income a percentage of the association ' s assets at the end of the income year. The income tax shall be carried out in accordance with the rules laid down in section 15, 16 and 16 A. Is the property negative, the income is assumed to be 0.

Paragraph 2. The form is the union's assets with deduction of the unifying liabilities. The balance of assets is suspended from goodwill and similar immaterial rights and suspensive rights and rights of use or requirements of the public or private nature of the association of the association and which are not subject to the granting of rights or services ; may be transferred. The balance sheet shall also be discharged from that part of the earnings surplus which, as divisive or after due, is being made for the income concerned. In addition, the shares in other cooperative groups shall be excluded from section 1 (2). 1, no. 3.

Paragraph 3. In the calculation of the assets, the assets and liabilities of the association shall be included in the commercial value on the day of reckoning, cf. however, paragraph 1 4-7.

Paragraph 4. Goods covered by the Act on the fiscal specification of lagers and so on, as well as livestock farming, which are subject to the rule of the fiscal treatment of livestock farming, are included in the value of the rules laid down in these laws.

Paragraph 5. Real estate shall be taken into account as per 1. In the income year of the income year, the property value laid down shall be deductible, or in cases where no property value is employed, the value of the commercial value per year, or in cases where no property value is employed. 1. October in the income year, cf. Two. Act. Real Estate, which includes at least 25 hectares of forest, is included in the 1. Act. the value added or the value of the trading value with a reduction of 40%. of the part of the property value or the value of the trade, which may be applied to forest.

Paragraph 6. Operating agents and ships covered by Chapter 2 of the depreciation Act shall be included in the calculation of the assets to the depreciation-entitled balance value at the end of the income year, cf. section 5 (5) of the Depreciation Act. Two, after deduction of the depreciation of the year. Negative balance cannot be deduce from the uptake of the assets.

Paragraph 7. Stocks are not freely transferable, and shares in companies in which at least 2/3 of all shares are owned by a single association shall be taken into account by the calculation of the assets at least 80%. of the commercial value.

Paragraph 8. In cases where an income period is shorter or longer than 12 months, a corresponding reduction or increase shall be made in section 15 (3). 2, and section 16 (4). 2, set percentages.

§ 15. Community associations which operate as a purchase associations so that the association of the association is intended to purchase, procreate or manufacture goods or provide services to the consumption of the Member States, in accordance with the rules laid down in paragraph 1. 2-4.

Paragraph 2. The entry shall be made up to 4%. of such a large part of the asset, which corresponds to the relationship between the turnover of the cooperative trade with members and the overall turnover, and 6%. of the remaining part of the property.

Paragraph 3. The addition of members shall constitute the sale of the cooperatits to Members for the exercise of the Member's holding or the holding of the members of the members of the Member States. Furthermore, the addition of members shall constitute sales to members of finished goods and formulants for use in production.

Paragraph 4. The addition of cooperatives which operate exclusively as purchasing associations, or with the trade unions in cooperatives referred to in Section 16 A, paragraph 1. 1 and not members shall be included in the decision-taking of the trade union by members and non-members respectively or in the calculation of the total turnover.

§ 16. Parts of activities such as production and sales associations, so that the association is intended to process, noble or sell the products or services of its members, make the income in accordance with the rules laid down in paragraph 1. 2-4.

Paragraph 2. The entry shall be made up to 4%. of such a large part of the asset, which corresponds to the relationship between the turnover of the cooperative trade with members and the overall turnover, and 6%. of the remaining part of the property. Inherit the turnover with non-members not 3%. However, for the total turnover, the income is estimated to be 4%. by the fortune.

Paragraph 3. The addition of members shall constitute the purchase of raw materials or products of the members of the members who are produced by members or by members associations, and the purchase of finished goods and excients of non-Member States for use in : production.

Paragraph 4. The addition of cooperatives which operate exclusively as production and sales associations, or with the production and sales associations in cooperatives referred to in Section 16 A (3). 1 and not members shall be included in the decision-taking of the trade union by members and non-members respectively or in the calculation of the total turnover.

§ 16 A. In the case of a cooperatiates which both operate as a purchase association, cf. section 15, and the production and sales association, cf. Section 16, the association must make a division of the company into a procurement function and a production and sales association. The distribution of the turnover shall be made separately for the two functions in accordance with the rules laid down in section 15 (1). 3, and section 16 (4). 3. The decision to have non-members turnover exceeds 25 pct., cf. Section 1 (1). 1, no. 3, shall be carried out on the basis of a weighted average of the two statements. However, the addition of non-members in the function of the largest turnover shall not, however, substantially or longer exceed 25% of the functions.

Paragraph 2. The marketing of the trade union with cooperatives which operate exclusively as a purchase association or trade union in cooperatives as referred to in paragraph 1. 1 which are not members shall not be taken into account in the circulation of turnover by members and non-members respectively or in the calculation of the total turnover. The turnover of the production and sales association with cooperatives solely as a production and sales association, or with the production and sales union in cooperatives as referred to in paragraph 1. 1 which are not members shall not be included in the calculation of the turnover of the production and sales assembly, with members and non-members respectively or in the calculation of the total turnover.

Paragraph 3. In the case of the cooperatits of trade and of the procurement and sales association of the trade union, the income statement must be carried out separately on the basis of the two forms of property in accordance with the rules laid down in section 15 (3). 2, and section 16 (4). 2. The income statement may, however, always be carried out on the basis of the total amount and weighted average of the two inventories in accordance with paragraph 1. ONE, ONE. and 2. Act.

TITLE IV

Calculation of income tax

§ 17. The income tax for the sections referred to in section 1 (1). 1, no. 1-2 b, 2-d-2 j and 3 a-6, and section 3 (1). 7, those companies and associations, etc. (corporation tax) is calculated by the taxable income and is 24,5%. for the income of the year 2014, 23.5%. for the income of the year 2015 and 22%. for the income year 2016 and subsequent revenue. Income included in the section 4 (4) of the hydrocarbon tax. 1 and 2, taxed by corporation tax rate after 1. Act. in Appendix of 0.5 percentage points for the income year 2014, 1.5 percentage points for the income year 2015 and 3 percentage points for the income year 2016 and subsequent income (additional company tax).

Paragraph 2. Where, in the taxable income, the income of one of the parties referred to in section 1 (1). 1, no. Paraguations 1 to 2 b, 2 (2) (2) and (3) a (3) (3) (b) and other associations, etcetera, benefit from companies which are or have been resident abroad and the yield is not covered by the tax exemption in section 13 (2). 1, no. 2, the beneficiary shall be reduced, the parent undertaking, the tax of the part corresponding to the ratio between the yield received and the income of the taxable income. However, a greater amount may not be reduced than the subsidiary undertaking, the subsidiary, and any subsidiary at lower level has been emitting tax on the part of the income which is due to the yield to the parent company. It is a condition that the provider-enoted company, the parent company, at any level shall own at least 10%. of the share capital of the profit-making company, the subsidiary, at the time of yield. 1.-3. Act. the corresponding use shall apply where the beneficiary is a corresponding company or association, etc., as referred to in section 2 (2). 1 (a) and the company or association, etc. are indigenous to the Faeroe Islands or Greenland, a State which is a member of the EU/EEA, or a State which has a double taxation agreement with Denmark. In the assessment of the presence of a company or association, etc., as referred to in section 2 (2). 1 (a) satisfies the condition of 3. PC shall be taken into account in the profit-making undertaking of the company or association, as well as the association or association.

Paragraph 3. If the taxable income is included in the income of companies whose shares are subject to the section 19 of the Asset Taxation Act and which are or have remained abroad, and the yield is not covered by the tax exemption in section 13 (3). 1, no. Paragraph 2, or of paragraph 4 of this paragraph. 2, the customs and tax administration may, in accordance with the application, comply with the undertaking ' s undertaking a part of the tax. However, a greater amount may not be paid than by the sum of the amount of the amount granted by the yields tax of the part of the income which is due to the yield and the amount to which the beneficiary company has been dislocated ; the tax of the corresponding part of the income exceeds the sum of the amounts which should have been depicted in taxes, respectively, where the profit-giving company should have been taxed here, respectively. In the country, for the yield of the income on the basis of the income.

Paragraph 4. If, with the foreign state, with Greenland or with the Faroe Islands, an agreement to avoid double taxation is concluded, however, no account shall be taken of the amount that may be left out, cf. paragraph The third country could be more taxable than those which this State, Greenland or the Faroe Islands have, after the agreement, has an unconditional requirement to discredit.

Paragraph 5. For the sections referred to in section 1 (1). 1, no. 5, said mutual insurance associations are counted income in commercial activities, cf. Section 1 (1). In its entirety, in its entirety, the taxable income is set out in its entirety. The other total income tax is, on the other hand, taxed only to the extent that it exceeds one million. DKK

§ 17 A. (Aphat)

§ 17 B. (Aphat)

§ 18. (Aphat)

§ 19. The income tax for the sections referred to in section 1 (1). 1, no. 3, mentioned cooperand (s) of the coop (s) constituted 14.3%. of the taxable income. For the income referred to in section 32, the treasure is the one in section 17 (4). 1, determined rate. In the calculation of the taxable income, which is taxed after 1. PC shall not be taken into account as part of the cooperatiates of the cooperatiates which consist of shares in companies covered by Section 32.

Paragraph 2. Taxable amounts in accordance with section 5 B (3). The fourth is taxed by 50%.

20. (Aphat)

§ 21. The income tax for the sections referred to in section 2 (2). Paraguations 1 (a), (b) and (f), shall constitute the one in section 17 (1). 1, the percentage of the taxable income. § 17, paragraph 1. Paragrites 2 and 3 shall apply mutatis muted, where the beneficiary is a corresponding company or association, etc. as referred to in section 2 (2). 1 (a) and the company or association, etc. are indigenous to a Member State of the European Union or of the EEA, on the Faroe Islands or in Greenland or a State which has a double-taxation agreement with Denmark. Section 13 (1). 1, no. TWO, SEVEN. pkt; shall apply mutatis muctis.

§ 22. Before the tax is calculated according to the preceding rules, the taxable amount shall be rounded up to the nearest 100-petal coresum.

-23. By the book by the rules of this law, income tax will fall to 15,24%. the municipality or municipalities in which the company or association etc. has run business, cf. the provisions of the Law on Provinal income tax. For the income of the year 2014, the rate is 13,68%. For the income of the year 2015, the rate of 14,27% is set.

Paragraph 2. The provisions of paragraph 1. Paragraph 1 shall not apply to DSB, Energinet.dk, Naviair, and Danpilot and their possible co-taxed subsidiaries.

Section V

Determination of lesions and collection

§ 24. Taxes after this law shall be leviated according to the general rules laid down by the tax legislation, insofar as they are applicable to companies and associations, etc., as provided for in this Act, the levying of the Act, except for Chapter 3, apply to : the levying of income tax by companies and associations, etc., shall apply to the extent to which it follows the application of the rules laid down in Chapter 5 of the Law.

§ 25. The tax minister lays down rules on the provision of man-made lists of tax-taxable companies and associations and so on.

SECTION 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 self-specification and notification of the choice of the execution shall be submitted before that date,

Paragraph 3. Customs and tax administration may disregard the deadline for the submission of the tax return on notification, 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 there are the assets to which the chaperone is concerned, the income of the peers, including the acrodite gains in the case of an abstention, etc., which should have been included in the calculation of the taxable income, if : 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 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 reference to the 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 sum due shall be due to the interest of the interest after the levying of the levying of Article 7 (3). 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%. p. a. The rate of payment of interest shall be 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 sum due shall be due to the interest of the interest after the levying of the levying of Article 7 (3). 2, with an appendix of 0,4 percentage points per. started month from the due date of the month.

§ 28. (Aphat)

§ 29. (Aphat)

§ 29 A. Companies and associations, etc., must pay the expected income tax of the income tax during the income year, in accordance with the year in question. however, section 30 A. Amounts paid during the income year shall be called the acontotax of the Member. Where the company or association and so on applies a different income other than the calendar year (staggered income), the payment tax paid for a given income shall be paid in the calendar year to which the income of the income is replaced.

Paragraph 2. Companies and associations, etc., must pay 50% in acontotax. of the average of the income tax of the last three income tax. This acontotax is referred to as ordinary acontotax. Ordinary acontotax is paid in 2 equal rates in the course of the income year and levied by customs and tax administration. For the collection of ordinary acontotax only amounts of which are equal to 1000 kr. If the prescribed acontotax is less than 2 000, however, it shall not be charged.

Paragraph 3. No ordinary acontotax is calculated for a company and so on which, by the latest available, tax is included in a collection tax after paragraph 31 or section 31 A, unless the company and so on is administration company, cf. Section 31 (1). 6, or Section 31 A (1). 4. for such a company and so on. 4 on the withdrawal of taxation by acontoontotax on the withdrawal of the tax burden.

Paragraph 4. Companies and associations, etc., which have been taxable in two incomes or less, can pay for the income of the acontotax at the latest by 20. March and the 20th. November of the income year. In the case of subsequent incomes, the company or association, etc., shall pay for the payment of the acontoontoonto 2. until the latest three incomes are available, the ordinary acontotax shall be calculated as 50%. of the average income tax of the present income tax.

Paragraph 5. Ordinary acontotax falls to payment in 2 instalments respectively on 1. March and 1. November of the income year. The last payment day is the 20th day of payment. at the month of the month. If the amount is not in a timely manner, it shall be forciled in accordance with section 7 (3). 1, cf. paragraph Two, in the levying law. The entanlation is the treasury of the treasury.

Paragraph 6. Companies and associations, etc., can voluntarily pay more acontotax. The payment of voluntary acontotax shall be carried out by the 20 of the 20. March and the 20th. November of the income year.

§ 29 B. Calculation of the company or association and other income tax, residual tax or surplus tax for the income year shall be carried out in accordance with paragraph 1. 2-10.

Paragraph 2. In the case of co-tax companies, etc. are calculated the total income tax, residual tax or excess income tax for the income year of the management company, cf. Section 31 (1). 6, or Section 31 A (1). 4. Acontotax for companies which, at the end of the year of earnings, are part of a tax calculation, are fully included in the tax calculation. When a company that does not form part of a taxation or all companies in a co-taxation in the course of an income shall establish a new group connection, cf. Section 31 C, and the income of the company or companies prior to the establishment of the conglomation is not included during the period of income of the income year, acontotax paid by the company or companies before the establishment of the conglomnial link instead of this income period. It is a condition that a request to this effect shall be submitted by the companies concerned no later than three months after the establishment of the group. No attachments are calculated in accordance with paragraph 1. 6 of the acontotax, as mentioned in 3. Act.

Paragraph 3. The company or association's and so on income tax for the income year shall be those in section 17 (3). 1, section 19-21-mentioned percentages of the taxable income.

Paragraph 4. The amount by which income tax may exceed the sum of ordinary acontotaxes, with the addition of any yield tax, cf. the section 67 (5) of the source. 2, regulated for addendum pursuant to paragraph 1. 6, and any voluntary acontopayments, shall also be regulated in accordance with paragraph 1. 6, the residual tax of the name. When calculating the residual tax, the ordinary acontotaxes are included, regardless of whether payment has been made. In the case of payment of the residual tax, a Treasurer shall be paid in addition to the amount referred to in paragraph 1. 7 fixed tax percent of the residue tax.

Paragraph 5. The amount of income tax may be less than the sum of ordinary acontotaxes in addition to any yield tax, as set out in the case of the tax on yield. the section 67 (5) of the source. 2, regulated for addendum pursuant to paragraph 1. 6 and any voluntary acontopayments shall also be regulated in accordance with paragraph 1. 6, name of excess tax. In calculating excess tax, the ordinary acontotaxes, regardless of whether payment has been made, has been made. In the repayment of excess tax, the company or association, etc., shall be reimbursed on the basis of paragraph 1. 7 fixed allowance percentage of the excess tax. There can only be repayment of sums actually paid. The tax administration shall transfer excess tax, including compensation to the tax account, no later than 2 banking days after the 20th. November of the calendar year after the year of the income or on a staggered income within two days of the day after the 20th of the 20th. November of the calendar year after the calendar year for which the advance income is replaced. Is it 20? However, the payment shall be transferred no later than 3 banking days after the 20th of November on a Saturday or Sunday. November. When disintegrating after paragraph 5 (5), ONE, ONE. PC or section 7 may be repaid by excess tax, however, before. In these cases, non-compensation shall be granted after 3. Act.

Paragraph 6. Voluntary acontopayments made, cf. § 29 A, paragraph 1 6, the supplement is calculated. In the case of voluntary acontopayments, which has been done at the latest 20. In March, the company or association shall be given a supplement in accordance with paragraph 1. 8. for voluntary acontopayments, which has occurred after the 20th. March, but no later than the 20th. In November, as well as for profit tax, the company or association, etc., shall pay a treasury ' s treasury as set out in accordance with paragraph 1. The same applies to payments as referred to in section 29 A (3). 4, and section 30 A (3). 8.

Paragraph 7. The approval rate shall be fixed annually and calculated as the reduced market interest rate after taxation multiplied by 480/360, rounded off to a decimal place. The reduced market interest rate by taxation shall be calculated as 25%. of interest in section 7 (4) ; TWO, THREE. PC, on the levying of taxes and levies, etc., with deduction of a proportion corresponding to the one in section 17 (3). 1%. The percentage tax rate shall be fixed annually and is calculated as the income of the income year for which 3.5 percentage points have been added.

Paragraph 8. The following paragraphs shall be laid down. 6 is calculated as a percentage of the voluntary acontoin charge. The percentage rate shall be fixed annually and shall be calculated as the reduced market interest after taxes shall be calculated in accordance with paragraph 1. 7, multiplied by 120/360, rounded off to a decimal place.

Niner. 9. Tax management and tax administration shall publish revenue percentage, residual tax rate and percentage by the income tax as referred to in paragraph 1. 6 at the latest 15. January. Where the company or association etc. uses a different income other than the calendar year (imprest income), the percentage of reimbursement, the percentage of residues and the percentage of the percentage shall be used in accordance with paragraph 1. 6, calculated on the basis of the interest rate of the market interest calculated on the basis of the interest rate at the end of the calendar year preceding the calendar year to which the income of the income takes place.

Paragraph 10. Supplement, interest and reimbursement in accordance with paragraph 1. 4-6 is not included in the taxable income.

§ 29 C. The institution or association, etc., shall determine that income conditions of the income year will differ substantially from the basis for determining the acontotax on the basis of section 29 A (3). 2 or 4, the company or association, etc., may depreciate that customs and tax administration reduce the ordinary acontotax, taking into account the expected income conditions of the company or association. Tax and tax administration shall place this information for reasons of reason, unless there is a basis for the fact that the company or association's and other information should be disregarded. The tax minister may lay down detailed rules on the form of the request and set a time limit for its submission.

§ 29 D. If the company or association, etc., may make it possible that the amount paid in Appendix of the yield tax and the provisions of paragraph 29 B (2) shall be subject to the payment of the sum. 6, will exceed the income tax income of the income year, the excess amount may be repaid in exceptional circumstances before the income year has been carried out. Payments shall not be paid until voluntary payments have been made after the 20. March, but no later than the 20th. November. After which profit shall be paid and then voluntary payments made by the 20. March. The annual acontotax of the income tax shall be reduced by the amount paid out to the extent that the amount exceeds the sum of tax returns and voluntary payments. For amounts paid in accordance with this provision, no allowance shall be granted, etc.

Paragraph 2. The application for reimbursement must be made to customs and tax administration before expiry of the deadline for the submission of tax return. However, where the conditions are in particular the case, customs and tax management may comply with a request made before the 1. October of the year in which the tax will take place.

§ 29 E. Companies and associations, etc., may for the income in which the company or the association, etc. are dissolved, etc. as referred to in section 5 (5). ONE, ONE. a point or section 7 without being covered by section 5 (5). 2, pay the income tax for final income within the same period as set out in Section 5 (5). 3, for notification of notification. Paid ordinary acontotaxes and voluntary acontopayments in accordance with section 29 A (3). 4 and 6, with the addition of any yield tax applicable to this income, shall be deemed to be voluntary payments after 1. Act. No attachments are calculated after paragraph 29 B (3). 6.

Paragraph 2. If the company or association may be able to make it possible to exceed the income tax, the excess income may be reimburse to the excess of the income tax until the tax is carried out. The request must be made to customs and tax administration before the expiry of the deadline for the submission of selfcation. No allowances shall be paid, etc. for the amount paid.

-$30. Tax and allowances after Section 29 B for companies and associations, etc. shall be payable on the 1. November of the calendar year after the year of the income or on a staggered income of 1. November of the calendar year after the calendar year for which the advance income is replaced.

Paragraph 2. If an increase in the tax rate is increased, the company or association, etc. shall pay the remaining tax or additional residues, the amount and allowances shall be paid in accordance with section 29 B (3). 4, for payment on 1. the month following notification of the increase, however, the earliest item in paragraph 1. 1 mentioned time. Where an increase in the tax rate is increased for a company or association, etc., that the excess tax is reduced or lapsed, the amount and reimbursement shall be reduced in accordance with section 29 B (3). 5, for payment on 1. the month following notification of the increase, however, the earliest item in paragraph 1. 1 mentioned time. Amouns referred to in 1. and 2. Act. shall be enclosed in accordance with section 7 (2). 1, cf. paragraph 2, in the charge of the levying of the law. started month from 1. November of the calendar year or at staggered income from 1. In November of the calendar year after the calendar year for which the advance income is replaced, and the month in which the collection is printed. The interest is not to be deducitable by the deducisation of the taxable income.

Paragraph 3. Restlevies, which are imposed on companies and associations, etc. on the basis of a recruitment of the income in which the company or association, etc. are dissolved, etc. as referred to in section 5 (5). ONE, ONE. PC, or Section 7 is due on the 1. the month following notification to the company or association, etc. for the employment. If the residual tax of the nearest income is not due in accordance with paragraph 1, 1, fall this at the same time. No residual taxis shall be levior after paragraph 29 B (1). FOUR, THREE. pkton, to the extent that the final income of the final income is paid within the quantity of the final income referred to in section 5 (5). 3, the deadline for submission of notification. If there is a company surplus tax for final income, no allowance shall be granted in accordance with section 29 B (3). 5.

Paragraph 4. Payment not later than 20. in the month in which the amount referred to in paragraph 1 is 1-3 due to payment shall be deemed to be timely. If the amount is not in a timely manner, it shall be forciled in accordance with section 7 (3). 1, cf. paragraph Two, in the levying law. Amounts and regular acontotaxes referred to in Section 29 A (3). 2, which is not paid in due time, shall also be recovered by the fees in accordance with the rules of the procedure for the recovery of taxes and other duties, etc.

Paragraph 5. Where a reduced tax is established for a company or association, etc., that a previously calculated residual tax shall be reduced or withdrawn, the amount and amendment shall be reimburcted to paragraph 29 B (2). 4, no later than 20. during the month following the reduction. Where a reduced tax is established for a company or association, etc., that any surplus tax or any additional excess tax shall be reimbursed with reimbursement after Section 29 B (3). Five, no later than 20. during the month following the reduction. Of those in 1. and 2. Act. the amount referred to shall be the company or association, etc., in accordance with section 7 (3). 1, cf. paragraph 2, in the charge of the levying of the law. started month from 1. November of the calendar year after the year of the income or on the basis of a staggered income of 1. November of the calendar year after the calendar year for which the advance income is replaced. The interest shall not be taken into account for the taxable income.

Paragraph 6. If a company or association etc. is in significant restance with the residues referred to in paragraph 1. 1 or 2 or with income tax as referred to in section 30 A (1). 1, customs and tax administration may decide that the taxes referred to above may be payable at the same time as the time limit for the submission of tax return, cf. Tax Control Act, section 4 (4). Two and four. If a company or association etc. is in substantial restance with the acontotax referred to in Section 29 A, customs and tax administration may decide that the taxes referred to above may be paid before the times specified in the provision. Customs and tax administration may also fix the number of instalments. Payment of residual tax, income tax, or acontotax no later than 20. the due month shall be deemed to be timely. Paragraph 4, 2. pkt; shall apply mutatis muctis. Customs and tax administration may at last decide that a company or association etc., which is covered by section 30 A (1), may be determined. 1 and, whatever the measures taken pursuant to 1. Act. remain in substantial revenues with income tax, shall be transferred to pay income tax during the income year in accordance with the rules of section 29 A.

Paragraph 7. The tax minister lays down rules on the administration of the acontoon tax, on the levying of income tax and so on and the balance of the amounts which, after section 23, fall to the municipalities.

§ 30 A. For companies and associations, etc., whose initial revenue has been initiated prior to the 29th. January 1992, which is not covered by 5. -8. pkt; the income tax shall be due to payment on 1. November of the calendar year following the income year, or at a staggered income, the 1. November of the calendar year after the calendar year for which the advance income is replaced. In these cases, Section 29 B shall apply by analogy to the calculation of residual tax and over-surplus tax. section 30 shall apply mutatis mutis to the payment of income tax and addendum. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 2 shall apply mutatis mutias to the repayment of yield tax. Anchor parties, whose depositors of anpartment capital of 1. In January 1997 or at least 200,000 shall pay the expected income tax of the income year in accordance with the rules of section 29 A, cf. $29 B-30. Companies and associations, etc., with a taxable income of 10 million. DKK in the case of the income year two years prior to the income concerned, income tax shall be paid during the income year in accordance with the rules of section 29 A, cf. $29 B-30. In the case of co-tax companies, etc. in accordance with section 31 and 31 A, the taxable income is the total taxable income (income tax) for the income year two years prior to the income concerned, and for parent undertakings, etc., compulsory consent according to section 32 is the taxable income of the parent company and so on taxable income for the income year two years prior to the income concerned. Has a company, etc. paid income tax after 5. -7. and, for subsequent incomes, acontotax shall also be paid.

Paragraph 2. Companies and associations, whose initial income has been initiated before the 29th. in January 1992 and which are not covered by paragraph 1. 1, 5. -8. PC, may choose to pay income tax during the income year. If a company or association and other arrangements are added to the system during the revenue of the first time, where the scheme is first applied, do not calculate orates in accordance with section 29 A (3). Two, for this income. The payments made by the Company or of the association in this year shall be considered as voluntary aconto payments in accordance with section 29 A (3). 6. The company or the association and so on for a given income income tax during the income year will also have to be paid for income tax during the income year later.

Paragraph 3. Companies and associations, etc., may for the income in which the company or association, etc. are dissolved, and so on, cf. Section 5 (5). ONE, ONE. point, or section 7, pay the income tax for final income within the same time limit as specified in section 5 (5). 3, for notification of notification. Has a company or association and so on by a voluntary payment of income tax after 1. .................... FOUR, THREE. pkt., for a residual balance of the balance. Has a company or association, etc., surplus tax for the final income shall be paid no compensation.

Paragraph 4. Where existing companies or associations, etc., which so far have not been taxable shall be transferred to a taxable undertaking, cf. Section 4, the company or association, etc., shall pay income tax during the income year.

Paragraph 5. Where such a change is entered for a company or association, etc., which is taxable in accordance with this Act, that future taxation must be carried out in the future, in accordance with other provisions of the law, the company or association, etc., shall pay income tax during the course of the year ; the income year.

Paragraph 6. If one or more of the concentration, division or transfer of assets covered by companies and so on shall pay income tax during the income year, the receiving companies, etc. shall pay income tax during the income year.

Paragraph 7. If two or more companies and other companies, etc., are subject to tax, cf. Section 31 and 31 A, and one or more of the companies, etc., must pay income tax during the income year, all those of the co-taxation involved must pay income tax over the income year.

Paragraph 8. Companies and associations, etc., which are covered by paragraph 1. 4-6, for the first two incomes, where section 29 A is applicable, the payment of acontotax shall not be paid at the latest 20. March and the 20th. November of the income year. For the subsequent revenue, Section 29 A (3) shall be found. FOUR, TWO. and 3. ptangle, equivalent use.

$30 B. The rules of this Act on the calculation of interest rates for a tax reduction shall not apply to cases where a corporation or association and so on shall have reduced its tax recruitment as a result of the company or association and so on paid compensation in the losses incurred by the State on taxes which have been incurred by another taxable person. Tax amounts which, after modifying the tax return, shall be repaid by the company or association, etc., enclosing with the same interest rate and for the same period as the replacement amount is rented. If the replacement amount contains interest rates, interest shall be calculated by the amount withheld by the same rate of interest and the same period used for the settlement of the damages. After the end of the two. and 3. Act. that period shall be calculated by the rate of interest paid by the interest rate, in accordance with the interest rate, until payment is made.

§ 30 C. To the extent that a replacement referred to in section 30 B is covered by the rules of payment or otherwise, the company or association, etc. shall be repaid, and so on, which previously are to be reduced, the company or association, etc., shall be reimbursed ; received in the context of the reduction of the tax reduction due to the compensation payment.

Paragraph 2. Repaid interest received pursuant to section 30 B may dedube from the taxable income.

Paragraph 3. In the paragraphs in paragraph 1. Paragraph 1 shall apply the rules on the calculation of interest rates in section 30 (3). 2, not applicable.

TITLE VI

Other provisions

§ 31. Corporate companies and associations, etc., covered by Section 1 (2). 1, no. 1-2 b, 2-d-2, 3 a-5 and 5 (b) 2 (2) (2), section 2 (2). Paraguation 1 (a) and (b) or the section 21 (b) of the hydrocarbon tax. 4, shall be subject to tax (national co-taxation). Corporate companies and associations, etc., shall mean companies and associations, etc., which at any time in the income year belong to the same group, cf. section 31 C, companies and associations, etc., which cannot be covered by section 12 (3). However, 2 and 3 shall not be deemed to be related to companies and associations, etc., which may be subject to section 12 (2). Two and three. in paragraph 1. 2-9 siblers fixed properties and affiliating activities after the coal-carbon tax system with fixed operating locations. For an ultimative parent company, the company that is parent company without being a subsidiary is the meaning of the undertaking, cf. § 31 C.

Paragraph 2. In the case of co-taxation companies, a co-tax income is made up of the sum of the taxable income for each company covered by tax law in accordance with the general rules of taxation applicable to the derogations applicable ; for cotaxed companies. Deposits in a fixed operating site may only be offset in the income of other companies if the rules of the foreign state, on the Faroes or Greenland where the company is established, will result in a deficit not to be included in the calculation of the company ' s undertaking, income statement of the foreign state, on the Faroes or Greenland Islands, where the company is established or where international tax is selected after Section 31 A. Before the tax on income is done, each surplus shall be offset by the first-surplus company ; the part of its own deficits of income periods prior to the amount of the tax to be spaced in ; positive income for income year. A company deficit of income periods prior to taxation can only be offset in the company's own profits. In this case, the loss of each surplus shall be the part of its own deficit of previous income periods during the period of taxation which can be spatial in the remaining positive income of the income year. Where there are both companies with positive income and companies having a negative income in tax, the share of the income deficit in the income tax can be distributed in the positive income of other companies, proportionately between the companies which have : positive income. If, after this, companies with positive income continue to be proportionate, the proportion of the remaining deficits of other companies are resisted from previous income periods during the income tax that can be spatient in the positive income of the income year. Where there are still companies with outstanding deficits in the income or remaining losses from previous income periods, these shall be transferred to offset in subsequent income by the rules on this subject. A company that resists deficits from previous income periods has to offset the oldest deficits first. A company deficit from previous income can only be offset by surpluses in another undertaking whose deficit has occurred in an income where the profit-making company has been co-taxed with the other company and the tax burden on the other, subsequent has been terminated.

Paragraph 3. § 12, paragraph 1. The two shall apply collectively to the tax collectively. § 12, paragraph 1. 2, shall apply only if the sum of the income of the tax on income in the income year is positive ; the total restriction after paragraph 12 (3). 2, is prorated between the pre-tax-based companies of the same tax collectors, cf. paragraph 2, 3., 5. and 7. in such a way that the equivalent of the proportion of the deficit corresponds to the ratio of the proportion of the total deficits referred to in paragraph 12 (2). 2, may be deducted in the income year and the total deficits that would be deducted in the income year if section 12 (3). 2, not applicable.

Paragraph 4. The recipient company in a tax-free restructuring after the Merger Tax Code cannot offset other tax-based companies and firm operational operations from revenue prior to the restructuring. 1. Act. shall not apply where the conniving company in the restructuring was included in a collection of taxation with the recipient company in the company or income in which the deficit occurred and the incoming company has not directly or indirectly participated in a tax-free party ; restructuring with non-co-taxed company in or after the deficit wound.

Paragraph 5. If there has not been a group connection with a company all year, income is included in that part of the income year, where there has been a group connection, cf. Section 31 C, in the calculation of the tax on the income of the tax. Tax depreciation, including the tax return, in accordance with section 18 of the depreciation Act, may be carried out in proportion to the amount of the revenue period forming part of a calendar year. At the time of the concert to be established or terminates, cf. Section 31 C is carried out after the general rules of the tax legislation for the period of income in question, which has been carried out, as though the period is an entirely income. The tax values and the choice of accrual principles, etc., which are laid down for the income statement at this time, are applied at the income statement for the remaining part of the income year. 1.-4. Act. applies, regardless of whether the company in question in connection with or after the end of the group connection is to be involved in a restructuring which is carried out with fiscal effect back at a time before the end of the group connection ; the establishment of. Establish group connection when acquiring a company which has not driven business prior to the establishment of the group connection and has the company ' s own funds from the foundation passed as a cash-indelified cash inhabitable ; the institution ' s financial institution shall be construed as established at the beginning of the income year and the income of the entire company ' s income for the income concerned shall be taken into account in the calculation of the tax on the income of the income. 6. Act. shall apply by analogy to the establishment of a new company, the extent to which the company is not attributing any assets or liabilities from companies that are not part of the group to be added to the foundation of a new company. If a company at the foundation becomes an ultimative parent company, six. and 7. Act. only at spines as referred to in 9. Act. and in the event of a share exchange, where there is no establishment or termination of the group connection between other companies. 1.-4. Act. does not apply to split an ultimative parent undertaking which has a subsidiary of a directly owned subsidiary, and as in the income concerned has not had any commercial activity other than to own the shares of the subsidiary, provided that the beneficiary companies are founded ; at the division or are companies, as mentioned in 6. Act. or, at the time of the division, the group connection between other companies shall be established or ceasing to be established.

Paragraph 6. In national consents, the senior parent undertaking participating in the area of taxation shall be designated as the management company in the tax. In the case of a Danish tax obligation not a Danish tax obligation, but several siblings of Danish tax-dutiable sweeteners, are appointed by one of the sister companies involved in the tax-management company. If the management company is no longer part of the group, or if another company becomes the top Danish parent company, a new management company must be appointed. The administration company's rights and obligations are transferred to the new administration company. The previous administration company must commit to the payment of an amount equal to the obligations that are transferred to the new management company. Payment as mentioned in 5. Act. has no fiscal consequences for the paying or the recipient. The management company shall make the payment of the total income tax. This also applies to residual taxes, addendum and interest. The tax administration may, with a free-making effect, pay excess tax and reimbursement to the administration company. The management company and co-tax companies, where all capital shares at the end of the income year are owned directly or indirectly by the ultimate parent undertaking, cf. Section 31 C shall be jointly jointly with the company of the part of the income tax, the acontoon taxes and the residues, and the allowances and interest rates, relating to the part of the income distributed to the company. Companies, where all capital shares at the end of the income year, have been owned directly or indirectly by the company or undertakings which shall be jointly and severally in the form of 10. and shall also show solidarity with the company. Ownership of ownership of the item 4 (4) of the exchange rate law. The shareholder ' s shareholder shall be taken into account in the calculation of holdings after 10. And 11. Act. In vain, there has been an attempt to make up for tax payments in the companies that are in favour of solidarity after 10. And 11. ., however, the claim may be applied to other companies in the area of taxation, but a maximum of the part of the requirement corresponding to the proportion of the capital of the undertaking owned directly or indirectly by the ultimate parent undertaking. If there is a company out of the same taxation, the performer shall be liable from the date of entry only to the part of the income tax, the acontoto tax and the residue tax and the allowances and interest rates which are to be distributed to the company, unless the same shareholder ' s shareholder, cf. Section 4 (4) of the exchange rate law. 2, continue to directly or indirectly possess more than half of the voting rights according to the withdrawal of the company.

Paragraph 7. All companies in the area of taxation shall make up the taxable income for the same period as the management company regardless of the financial year according to company law rules, cf. ~ 10 (1)) 5.

Paragraph 8. In the case of the use of deficits in Danish companies and fixed operating establishments in Denmark, the management company must commit to payment to the underage party of an amount equal to the one in section 17 (3). 1% (tax value) of the utilised deficit at the latest on the day of the timely tax payment after section 30. Danish companies and firm operating locations in Denmark, which are exploiting deficits in Danish companies or firm operating sites in Denmark, shall commit to the payment to the management company of an amount equal to the tax value of the deficit execution. Payment commitments after 1. and 2. Act. may be omitted if another group company, cf. Section 31 C pays the sub-deficit for the grant execution. It is a condition that this other group company without taxation, cf. Section 31 D can grant grants to the company that is taking advantage of the deficit. Danish companies and firm operating locations in Denmark, whose income tax is paid by the management company, must commit to the administration undertaking of an amount equal to the income tax paid. The payments referred to in this paragraph shall have no fiscal consequences for the paying or the recipient.

Niner. 9. In the calculation of the taxable income, a co-taxed farm operation in Denmark or a coated subsidiary in Denmark may choose to overlook the deficit that is transferred to offset in its income from other tax-based companies or fixed operating points under the rules laid down in paragraph 1. It is a condition that the fixed operation of the subsidiary of the subsidiary of the subsidiary of the income from the income statement abroad and the relaxation of the Danish tax in question is equivalent to the method of relaxation in the section 33 of the body of the body. The amount of money discarding shall be proportionate to the individual sub-subsidy sources and shall be accompanied, together with any remaining deficits applicable to subsequent incomes, in accordance with the rules laid down in § 12.

§ 31 A. The ultimate parent company may choose that the co-taxation of companies and associations, etc., which are co-taxed in accordance with paragraph 31, shall also apply to all groups of companies and associations, etc., in which none of the participants are concerned ; shall be liable for the undertaking ' s obligations and which distributes the profits from the capital of the participants (international co-taxation). The choice shall also apply to all fixed operating premises and fixed properties situated abroad and belonging to the tax and other undertakings and associations, etc., in section 31 concerning national collectives, shall apply by analogy. application of international intertaxation with the additions and derogations provided for in paragraph 1. 2-14. 1.-3. Act. the corresponding use shall apply to a company and so on as mentioned in section 31 (3). 1, which are not conjoined by other Danish companies, etc., fixed properties or fixed operating establishments located in Denmark. in paragraph 1. 2-13 are fixed properties and affiliating activities after the coal-carbon tent, with fixed operating establishments.

Paragraph 2. Subgunfire in foreign companies and fixed operating points for income periods prior to the entry of the taxation system shall not be deduct in future profits. Expenditure in foreign companies held before cotaxation can only be deductible in the taxable income if, at the time of the time of withdrawal, the deduction was deductible on the basis of Article 2, where the interruption of international cooperation can be disconnected deficits in foreign companies and fixed operating establishments shall not be carried out in the offsetting in future incomes. Deduction for group contributions by foreign rules shall be made by foreign collectible companies in the Danish income statement, provided that the group contribution is also included in the Danish income statement of a company which is co-taxed with the first-mentioned company.

Paragraph 3. Election of international taxation is to be carried out at the latest in the time of the submission of tax return on the first income in which international co-taxation is chosen. If the elections are not entered in a timely manner, international consent shall be considered to be deduced from the absence of a timely choice. Election of international co-taxation is binding on the parent company for a period of 10 years, cf. Six. and 7. Act. At the end of this period, international consent may be equivalent to a new 10-year period of time. The boning period for the ultimate parent company remains the same, even though the group of companies connected or diminishes. The ultimate parent company may choose to terminate the binding period with full retaxation to follow, cf. paragraph 11. The interruption must be notified not later than in the context of the timely tax return on the income from which the international co-tax is being disconnected. If the ultimate parent company becomes a subsidiary of another ultimate parent company, the binding period for the first-parent parent undertaking (the purchased parent company) and its subsidiaries shall be deemed to have been suspended with full recovery for the purposes of full recovery, cf. paragraph 11, unless the purchased parent undertaking and its subsidiaries are included in a possible binding period for the new ultimate parent undertaking. If the same shareholder ' s shareholder, cf. Section 4 (4) of the exchange rate law. In addition, the period of direct or indirect use of more than half of the voting rights in the purchased parent company shall be used for the parent undertaking of the most recently selected international co-tax. No matter 9. Act. the use of the binding period for the purchased parent company has been unchanged, provided that the new parent undertaking is newly acquired. By splitting the ultimate parent company the binding period shall be deemed to be disconnected and full retaxation shall be carried out in accordance with paragraph 1. In the case of mergers between companies which are the ultimate parent companies in each of its groups, international cooperation shall be deemed to have been chosen if the group with the largest consolidated own funds has opted for international taxation. In that case the binding period for the ultimate parent company of this group shall be used. Otherwise, the binding period will terminate and full retaxation shall be carried out, cf. paragraph 11, unless the recipient company selects international intertaxation.

Paragraph 4. In international intertaxation, the ultimate parent company is the management company. If the ultimate parent company is not taxable in accordance with section 1 or 2 or not in the collection of taxation, an administrative party which is covered by Section 31 (1) shall be designated. 1. The following shall be applied in accordance with the same criteria as in section 31 (3). 6. The ultimate parent company shall be jointly with undertakings covered by Section 31 (3). 6, 10. pkton, income tax, acontotax, residual tax and allowances and rates of income as well as the administrative company ' s potential retaxing obligation. Section 31 (1). SIX, 13. And 14. pkt; shall apply mutatis muctis. The charge does not include income tax and so on of income that would form part of the tax revenue after paragraph 31, if no international tax were chosen. The dedushness of taxation on the exploitation of deficits abroad must be considered separately as a deferred tax obligation in the management company ' s annual accounts.

Paragraph 5. If the administration company ceades to be a tax obligation to Denmark after sections 1 or 2 or the management company no longer forms part of the group, the full recovery of the management company shall be replaced by full retaxation, cf. paragraph 11. 1. Act. shall not apply where a new management company is appointed, cf. paragraph 4.

Paragraph 6. In the case of the exploitation of deficits in foreign companies and fixed operating places abroad, the company or place to use the deficit must commit to the payment of an amount equal to the tax value of the deficit to : management company. Foreign companies, whose income tax is paid by the management company, may commit to the payment of an amount equal to the paid income tax to the management company. The obligation to pay after 2. Act. the Administration Company may also be taken into account by Danish companies or fixed operating establishments in Denmark, provided that the latter company and the foreign company are part of another branch of the group than the management company. The payments referred to in this paragraph shall have no fiscal consequences for the paying or the recipient.

Paragraph 7. Where a foreign company and so or a firm operating facility is included in a collection of taxation, assets and liabilities not already covered by Danish taxation shall be deemed to have been procured by the actual purchase of the commercial value at the beginning of the contract ; of the initial income, in accordance with the amount of tax, cf. however, paragraph 1 8. The purchase price of immovable property shall be reduced by any profit relating to real estate in Denmark, cf. § 8 (3) 2, and OJ L 6 A and 6 C, no acquisition sum shall be fixed on goodwill or any other immaterial assets referred to in Section 40 of the Depreciation Act, to the extent that they have been worked by the company itself. the sum of the sum of goodwill and other immaterial assets can be counted at a maximum of the difference between the sum of the sales sum and the trade value at the time of intra-taxation participation.

Paragraph 8. Depreciation-entitled assets are considered to be acquired for the actual acquisition sum, and they are considered to be acquired on the actual purchase of the acquisition. Are depreciation-entitled assets acquired from a group-related company, cf. Section 4 (4) of the exchange rate law. 2, without the transfer having resulted in Danish or foreign taxation of any recurrent depreciation, gains or losses, or the foreign tax on the transfer has been deferred, the company or firm operating office shall be entered in the case of the transfer of the proceeds ; shall be included in the collection of taxes, in the acquisition and acquisition times of the transferable company. The depreciation-entitled assets shall be deemed to have been written to a maximum of Danish rules until the beginning of the first income in the form of taxation. This calculation applies to the rules of the income in which the tax on taxation is started. However, the assets shall be regarded as acquired for the commercial value at the beginning of the first income under cotaxation, provided that this value is less than the value calculated in accordance with 1. -4. Act. Are goodwill or other immaterial assets, as mentioned in the section 40 of a group-connected company, cf. Section 4 (4) of the exchange rate law. 2, and are the work of the delegating company or other group-related companies, the assets shall be regarded as having been under the 2. Act. the conditions laid down in the calculation of the taxable income for the establishment of the company or fixed operating establishment, which is involved in the tax return. 2. and 6. Act. however, apply, although Danish taxation has not been done in the case of a full Danish tax due to the maximum amount to be counted by an amount equal to the difference between the sum and the value of the commercial value at the time of the sale of goods ; participation under Danish taxation. To the extent that there has been tax, as has been mentioned in 7. .. The sum of the purchase price shall be increased by the profit made by the transferor in the income of the taxable income.

Niner. 9. Recycled depreciation of assets deemed to be pre-deducted prior to deduction may not exceed the amount by which the sum of the depreciation of the resulting depreciation in the amount of tax is greater than the actual value loss after : participation in cotaxation. The only thing in relation to the purchase price can be counted at a maximum of a sum equal to the difference between the sales sum and the commercial value at the time of intra-tax participation. For assets written in accordance with the hymometer, the sum of the sum to the written value shall be assumed at the time of the time of departure, with the addendum of revaluation and profit after 1. and 2. Act.

Paragraph 10. If a co-tax with a foreign company and so or a firm operating point of a Danish company and so on ceases as a result of the fact that international cooperation is not selected at the end of the binding period, the administration company ' s income shall be increased for it, income in which the tax is to be terminated by means of an amount equal to the profit made by the foreign company or the fixed farm place at the end of the business and sale to commercial value of assets and liabilities, which are intact ; the company shall, respectively, be the firm operating point of the termination of the termination (ordinary gene tax), cf. however, paragraph 1 12. The administration of the Administrative Company may be increased by an amount equal to the retaxing balance divided by the amount referred to in Section 17 (3). 1% in the income year of the ordinary gene taxation. The recharge balance shall be recharged per country as an amount equal to the tax value of the deficits to which foreign companies or fixed operating establishments in the country concerned have been collectively held in the tax periods from other companies or fixed income from other parties ; operating places and which are not matched by the tax value of later years of profit reduction shall be deduced from any creditrelief, and the tax value of any retaxation after 6. Act. The retaxing balance is not reduced by tax returns, to the extent that profits are due to interest revenues and exchange gains on companies in the tax return. Tax value in 3. Act. is calculated with the one in section 17 (3). One, the percentage of the income that has been given is the advantage of where the deficits have been exploited, where the profits or revenues are taxed. 1.-5. Act. shall apply by analogy if a foreign company, etc., or a Danish company, etc., with a fixed operating point of the country, is no longer part of the group. 6. Act. shall not be applicable if the company ceasing and the assets and liabilities in the case of fusion or fission are deposits in a company which is part of the tax.

Paragraph 11. If international co-taxation is disconnected from the end of the binding period, the income of the administration company for the income in which the tax is stopped, with an amount equal to all existing revenues, has been divided by an amount equal to all existing retaxing (s) ; the one in section 17 (3). 1, the percentage plus retaxing balances according to section 33 D (full retaxation).

Nock. 12. Condues a double taxation agreement that Denmark shall be leaned to surpluses in a fixed operating location according to the sample method, section 33 D shall apply to surpluses and deficits in such fixed operating establishments.

Paragraph 13. Foreign subsidiaries have no deduction of interest and royalty payments if the income of the corresponding income would result in limited tax obligations, in accordance with paragraph 2 (2) of this Regulation. 1 (d) (g) or (h) if the payment is derived from sources here in that country. Foreign subsidiaries shall not deduction from expenditure on expenditure if the corresponding income of the expenditure shall be deemed to have been an internal benefit. The revenue shall be deemed to be an internal benefit if the beneficiary of the income and foreign subsidiary in accordance with the rules of a foreign state is treated as transparent entities of the same legal persons, thereby deemed to have the revenue of : be an internal benefit in the State concerned and shall not be taken into account in the inventory of the income. 3. Act. shall apply only if the foreign state, the Faroe Islands, or Greenland is a member of the EU or the EEA, or has a double taxation agreement with Denmark. The provisions of 2. 4. Act. shall not apply where the corresponding income is taxed in Denmark, on the Faroe Islands or Greenland or in a foreign state, a member of the EU or the EEA, or a double-taxation agreement with Denmark.

Paragraph 14. A company is deemed to be foreign if it is established in a foreign state, on the Faroe Islands or Greenland, including, in accordance with the provisions of a double-tax agreement.

§ 31 B. The tax rate sets out how to proceed with the entry into force and withdrawal of taxation. The tax rate may lay down specific rules for conversion of the result of the annual result of foreign currency to Danish kroner on the start of international taxation. The rate of tax may permit the conversion of income by the establishment of the group connection in a different manner other than prescribed in section 10 (1). 5 whose administrative account is given to the companies and no special tax advantages are achieved at this time. The tax can decide that decisions on reorganization of income are after 3. Act. shall be taken by customs and tax administration. The rate of tax shall determine the information which is relevant to the tax and tax calculation of taxes in addition to the customs duties referred to in paragraph 1. 2 was mentioned and the information to be provided at the request of the Commission. The tax rate may lay down rules for the administration company's information and documentation to be required under the section 3 B of the Tax Control Act on controlled transactions between tax-related companies.

Paragraph 2. In the case of self-disclosure, the Administration Company shall provide information enabling the control of ownership of the ownership of the ultimate parent company and in the other companies. The sellout of the tax on the income tax must include retaxing balances in accordance with the same amount of tax revenue. § 31 A, paragraph. 10, 3. pkt., and paragraph. 12. Selvanti saldi, after the taking of a tax contract, is part of this.

Paragraph 3. If sufficient information is not provided, international cooperation may be interrupted by the Tax Council, in accordance with the customs and tax administration. The disruption of international co-taxation triggers full retaxation, cf. § 31 A, paragraph. 11, with effect from, and with the income, where sufficient information has not been provided.

§ 31 C. A company, a foundation, a trust, or a union, and so on. (The parent company), together with one or more subsidiaries, a group. A company can only have one direct parent company. If several companies comply with one or more of the criteria referred to in paragraph 1, Two-six, it is only the company that actually exercises the dominant influence over the economic and operational decisions of the company, which is considered to be parent.

Paragraph 2. The power of determination is the power to control a subsidiary's economic and operational decisions.

Paragraph 3. Determining influence in relation to a subsidiary shall be available when the parent undertaking, directly or indirectly through a subsidiary, owns more than half of the voting rights in a company, unless in specific cases it may be clearly demonstrated that a such ownership does not determine the influence of such ownership.

Paragraph 4. If the parent company has a parent company no more than half of the voting rights in a company, the parent company shall have an influence.

1) raw more than half of the voting rights in the power of a market with other investors ;

2) the power to control the financial and operational conditions of a company in accordance with a statute or agreement ;

3) the power to designate or dismiss the majority of the members of the executive body and this body has the determining influence on the company or ;

4) the actual majority of the votes of the general assembly or in a similar body, and in so doing, possess the actual determining influence over the company.

Paragraph 5. The existence and the impact of potential voting rights, including design and purchase options on shareholdings which are currently available to be utilized or converted, must be taken into account when assessing the influence of a company.

Paragraph 6. In the calculation of voting rights in a subsidiary, the voting rights shall be disregarded from voting rights which are linked to capital shares held by the subsidiary or its subsidiary undertakings.

Paragraph 7. Achieving a determinant influence over one or more companies, etc. through the group connection in the section 4 (4) of the course of the exchange rate. 5, these companies, etc shall not be regarded as the subsidiaries of the acquiring company in relation to stk.1.

Paragraph 8. A company being taken under bankruptcy proceedings must be kept out of the line of taxation from and with the income in which the bankruptcy decree is terminated. At the termination of the collection of taxation, Section 31 A (1) shall be subject to : 10, use.

§ 31 D. In the calculation of the taxable income, companies and associations, and so on, do not include grants from corporate companies or associations, etc., in accordance with. Section 31 C, however, only if the beneficiary directly or indirectly is parent company of the grant consignee, or the grant of the beneficiary and the beneficiary shall have a joint direct or indirect parent company (sister-companies). In the case of a subsidy between two companies (sister-companies), with a joint direct or indirect parent undertaking, 1. Act. use only if the joint parent undertaking may receive tax-free benefits from the subsidy-sylar. If the common parent company is only the owner of the acidity, the conditions must be met in each owner's indent. Where the common parent undertaking or the intermediary is foreign, they must be covered by Directive 2011 /96/EU or meet the conditions of deduction or reduction of yield tax in accordance with the provisions of a Member State ; a double tax agreement between Denmark and a foreign state, the Faroe Islands or Greenland.

Paragraph 2. Paragraph 1 does not include profit-out loins.

Paragraph 3. Companies providing grants to corporate companies, cf. Section 31 C, in no case has a deduction for the subsidy.

Paragraph 4. The beneficiary and the consignee shall be companies and associations, etc., which shall be taxed in accordance with section 31, or companies and associations, etc., which are subject to tax or would be subject to tax after paragraph 31 A. the rules of the asset tax on the law.

Paragraph 5. Notwithstanding paragraph 1 1 include group supplements at the income statement provided that a foreign group-related company has deduction from the group tax on foreign tax rules.

Paragraph 6. It is not considered to be a tax allowance for the intermediary of the intermediary, when sums considered to be received by the shareholder according to section 4 A (4) (A) of the stock market. 3, or § 4 B (4), Two, do not be desolated to the shareholder.

§ 32. If a company or association, etc., as referred to in section 1 or 2 (2), Paragraph 1 (a) is a parent company of a company or association, etc., (Subsidiary), cf. paragraph 6, in the income statement, the parent company shall include the amount set forth in paragraph 1. 7-10, when the amount is positive. Owes the share of the share capital of a subsidiary, directly or indirectly by several parent undertakings, shall be taken into account in the parent undertaking which owns the largest direct or indirect ownership share. If several parent companies are of equal shares, the proportion shall be included in the top parent company. This is a precondition for taxation after 1. point that the following conditions are present :

1) The data company's CFC income, cf. paragraph In the income year more than half of the total taxable income of the subsidiary shall be discharged in accordance with paragraph 1. In the case of the assessment, taxable income from companies under the dominant influence of the subsidiary shall be disregarded if companies are resident in the same country as the subsidiary. Instead, taxable income in the companies concerned shall be proportionate in accordance with the direct or indirect ownership share of the subsidiary. In the calculation of the subsidiary income of the subsidiary, the income of the subsidiary income shall be discharged from taxable subsidies.

2) The financial assets of the data company in the income year shall be more than 10%. of the company ' s total assets. For the purposes of financial assets, assets whose return is subject to paragraph 1. 5. The decision shall be made on the basis of the valuation values, including intangible assets, the return of which is subject to paragraph 1. 5, no. 6, for commercial values. Assets whose returns are tax-free shall not be included in the inventory. Exerunted claims on goods debtors etc. are not part of the inventory. In the assessment, no. ONE, TWO. and 3. ptangle, equivalent use.

3) The company ' s shares in the subsidiary company are not shares or investment firms, etc. in investment firms, in accordance with the rules of the Asset Taxation Act.

4) The company ' s shares of the parent company are not owned by a legal person taxed in accordance with the rules laid down in § 13 F.

Paragraph 2. Paragraph 1 shall not apply if the group has opted for international intertax according to section 31 A to allow a subsidiary with concession to carry out insurance, mortgage broker, investment manager, or investment management, or banking, and subject to public supervision, shall not be subject to paragraph 1. 1 if the principal part of the income comes from the business of customers in the country where the subsidiary is indigenous, the principal part of the income comes from the business with customers who are not affiliates with the subsidiary, cf. Section 2 (2) of the body of the body. 2, and the subsidiary company ' s capital base does not exceed the operation of the operation of the insurance, mortgage broker, investment management or banking undertaking. It is a condition that the subsidiary company is Danish, or that the tax on the yield from the subsidiary to the parent company will be waived or reduced in accordance with the provisions of Directive 2011 /96/EU or after the double-taxation agreement with Faeroes, Greenland or the State in which the subsidiary company is based. The rate of tax shall lay down conditions for the authorisation which cannot exceed 10 incomes.

Paragraph 3. The income and assets of the subsidiary shall be discharged according to the territorial principle, cf. § 8 (3) 2, 1. 3. Act. Paragle1, 2 and 4 to 13 shall apply mutatis muted to the fixed operating premises of the subsidiary situated outside the State in which the subsidiary is established.

Paragraph 4. In the case of the calculation of a Danish subsidiary CFC income and its subsidiary tax income, the subsidiary company ' s own income statement is used without the inflow of losses from previous income. Where a foreign subsidiary CFC income and its total taxable income are charged, taxable profit and deductible losses shall be calculated on the basis of the actual amounts of acquisition and the actual amount of the actual purchase ; purchase time of purchase unless the storage principle is to be used. Depreciation-entitled assets are considered to be acquired for the actual acquisition sum and written by the total foreign tax depreciation. Selecting a subsidiary of a income with a positive foreign income is not to reduce this to the greatest possible extent by exploiting foreign depreciation options, or a foreign depreciation basis cannot be used in section 31 A (3). 8. Depreciation and other expenditure which, according to the choice of the taxpayer in accordance with Danish rules, can be deduculate in the income concerned, shall be deducciary if the subsidiary undertaking by the decision of the taxable income by foreign rules is carried out ; corresponding deduction in the same income. 2.-5. Act. shall not apply where a Danish tax value is already provided for the assets and liabilities concerned. If the subsidiary of the income tax return on foreign rules has been entered into the acquisition and acquisition times of a deposited company, also be timed into the field of purchase and purchase times of the Danish income statement. If a transfer is made to another undertaking in which the recipient company will enter its subsidiary sums and acquisition times, and the parent company after the transfer continues to be a parent to it receiving company shall not include profit and loss in the Danish income statement.

Paragraph 5. The CFC revenue shall be calculated as the sum of the following revenue and expenditure :

1) Taxable interest income and deductible interest expenses.

2) Taxable gains and deductible losses of debts, debts or financial contracts covered by the exchange rate law. Gains and losses on contracts (termination contracts etc.) serving for the management of operating income and operating costs are not included. However, the fees and losses on terminates, etc. shall be taken into account if the taxable exercise is sustenance by the purchase and sale of claims and financial contracts, or operating nutritional activities by financing.

3) Provision and lignments, which are deductible from the section 8 of the body of the body. 3, and the corresponding tax-compulsory commissions and similar provisions.

4) Taxable yields and taxable abstentions relating to shares, etc., which are covered by the tax burden on the part of the stock market.

5) Taxable profits and losses in respect of shares, etc., which are covered by the tax burden on the part of the stock market.

6) Payments of any kind received as remuneration for the use or the right to use immaterial assets and profits and losses by the loss of intangible assets. 1. Act. does not, however, apply in the case of payments from companies which are not affiliated with the subsidiary, cf. Section 31 C, for the use or the right to use intangible assets that are caused by the subsidiary's own research and development activities. Intangible assets shall include any copyright in a literary, artistic or scientific work, including feature films, any patent, trade mark or pattern, or any model, drawing, secret formula or method of manufacture, or information on industrial, commercial or scientific experience.

7) Tax deductions relating to revenues as referred to in point (2) 1-6.

8) Taxable income at financial leasing, including profit and loss of assets that have been used for financial leasing.

9) Taxable income in relation to insurance, business as money or credit institution or financial activities, by the way.

10) Taxable profit and loss in terms of the loss of CO 2 -quotas and CO 2 -Credits, cf. Section 40 A of depreciation.

Paragraph 6. The company shall be regarded as a parent undertaking of the subsidiary, if the undertaking is a direct or indirect shareholder of the subsidiary and the group has a dominant influence on the subsidiary after Section 31 C ; by the judgment of the dominant influence ; include voting rights etc., which are possessed by individual shareholders and their presence, cf. Section 16 H (3) of the body of the body. 6, or of a fund or trust set by the near-standing, etc., or of funds or of the foundations of such a fund. Similarly, the voting rights shall include voting rights, etc., which are included by members of company members, with whom the parent company has an agreement on the exercise of control, or as a company or association, etc. as mentioned in Section 2 (2) of the body of the body. ONE, TWO. Act. (transparent unit) in which the parent company is participating.

Paragraph 7. The income statement of the parent company shall be counted as part of the subsidiary ' s income corresponding to the average direct or indirect proportion of the subsidiary capital of the subsidiary that the parent undertaking has owned during the income period. However, income is only earned by the subsidiary of that part of the parent company's income, where the group determines the influence of the subsidiary.

Paragraph 8. In the determination of the subsidiary assets and liabilities acquired or processed before the group was given a dominant influence in the subsidiary, the commercial value at the time the group managed to get control of the subsidiary company shall be used in : the place of the purchase price. § 4 A, paragraph 1 ONE, TWO. and 3. pkt; shall apply mutatis muctis. When the subsidiary meets the conditions laid down in paragraph 1 However, without having fulfilled them in the preceding income, the assets shall be deemed to have been written off by the foreign tax depreciation of the preceding revenue, subject to paragraph 1. FOUR, FOUR. ptangle, equivalent use. Recycled depreciation may not exceed the amount by which the sum of depreciation carried out this year in the year of taxation after that provision exceeds the actual loss of life after the date when the group managed to get control of the subsidiary. 1.-4. Act. apply only where profits and losses on the assets and liabilities in question are not already included in the Danish income statement. If a transfer is made to another undertaking in which the recipient company for foreign rules enters the acquisition and acquisition times of its subsidiary and the parent company after the transfer continues to be a parent undertaking receiving company having the same direct or indirect ownership share, account shall be taken of profits and losses not at the Danish income statement.

Niner. 9. The income statement of the parent company shall be counted as the subsidiary deficit of the subsidiary. Similarly, there are deficits that have been transferred from other companies as part of a co-taxation or other regulatory framework whereby deficits can be transferred. However, the transfer and transferred deficit of the data company may not exceed the maximum amount equal to the deficit in accordance with Danish rules. The section 33 H of the Lime Code shall apply mutatis muted to the parent company ' s own deficits, which cannot be resilient in the subsidiary of the subsidiary.

Paragraph 10. Where the parent undertaking directly or indirectly takes down its ownership share in the subsidiary company, the assessment of whether or not the parent undertaking shall include the income of its subsidiary, and the income from the parent undertaking, shall include the income which, the subsidiary would have carried out if it had passed all the assets and liabilities covered by the exchange rate law and the value of the equity tax on the commercial value at the same time, but not more than an amount proportionately equivalent to that of the trade ; Equity share. In the same way, tax provisions shall be included in the subsidiary. In income after 1. and 2. Act. deduct the taxable income from which the parent company is co-relying on the section 17 of the Asset Taxation Act as a result of the asset transfer, without, however, the deduction may not exceed the income of 1. and 2. Act. 1. and 2. Act. shall not apply where the parent company continues to be parent company of its subsidiary. There is, however, a proportionate tax, to the extent to which the ownership of the motherhood is reduced. 1. and 2. Act. does not apply if the shares are transferred directly or indirectly to a close, subject to the section 16 H of the body of the body of the body, or to a corporation tax company, cf. § 31. The immediate, respectively, the co-taxed company shall enter into the accounts and hours of the parent undertaking in accordance with paragraph 1. However, there is a proportionate taxation, to the extent that the ownership share is reduced.

Paragraph 11. A reduction shall be given to the Danish and foreign taxes of the subsidiary in accordance with Article 33 (3) of the body of the body. One and six. The taxes on taxes which the subsidiary would pay if they were taxed in accordance with the principle of Article 8 (2) of the principle of the principle of the territory of the Member State of the Union shall be discharged. 2. If the parent company at the revenue return account must be a profit on assets and liabilities in accordance with paragraph 1. 10 shall be awarded for the tax to be imposed on the income of the subsidiary on the asset or the passivity of the subsidiary, if it were not at the same time. Impact after 3. Act. however, the Danish tax on the income of paragraph 1 cannot exceed the Danish tax. 10, 1. Act. There is a reduction in tax provisions pursuant to paragraph 1. 10 shall be equivalent in accordance with the following 3. and 4. Act.

Nock. 12. The tax rate may be laid down for the drawing up of accounts for foreign companies. Where the conditions for CFC taxation are met only in part of the parent company ' s income, account shall be paid to the subsidiary company for this period.

Paragraph 13. If a parent company has paid the tax of a foreign subsidiary income for an income after this provision, this tax may be offset in the parent undertaking of the parent undertaking in a later income, to the extent the sum of the subsidiary paid. Taxes as referred to in paragraph 1. 11 and the paid tax as a result of this provision exceed the sum of the Danish tax on the income of the subsidiary of the relevant and intermediate income. Amounts that cannot be spatial in the other taxes of the parent company shall be paid in cash. The 3 revenue that precedes the first income is where the subsidiary meets the conditions laid down in paragraph 1. 1 may be taken into account in the calculation after 1. Act. This paragraph shall apply only if, throughout the period, the group has a dominant influence in the subsidiary, cf. paragraph 6.

§ 33. Where an association or association, etc. dissolved and assets shall be furnishing to shareholders or members without adequate resources being provided to cover the income tax or the association of income tax, the shareholders and members are also provided ; in the case of the liquidator or in the case of an unelected or appointed management board, jointly responsible for the payment of the tax. In the case of liquidator (Administrative Board), the solidarity responsibility cannot be made in respect of a greater amount than the sum of those for shareholders or members made available, and shareholders or members are responsible only to the extent to which they have received ; the encoding from the association. However, this does not apply in the case of the suspension of limited liability companies and anti-party companies, in accordance with section 216, in the Act of Company and Company Law or other companies, in accordance with section 20 a in the law of certain operators.

§ 33 A. The transferability of capital shares in a company shall be liable for the payment of the taxes and charges payable by the company as a current or latent obligation on the transfer date. The charge can only be applied if it is not tried in vain at the company. Furthermore, the charge may be applied only when the transferor at the time of transfer knew or should know that the transferee paid for the shares or the parties concerned. Where the transferee is a company and so that is not fully taxed in this country, liability may apply directly to here in the country fully taxable persons and companies to the extent that these directly or indirectly have a determinant ; influence over the transferable company. Determining influence shall always be available if, in this country, they are fully taxable persons or companies, by means of ownership or by means of voting rights, directly or indirectly, the owner of more than 50% shall be the owner of this country. of the stock capital or at its disposal more than 50%. of the voices in the company. This is a condition of liability after 4. a point that, at the time of the transfer, they knew or should know that the transferee paid overprice for the shares or the parties concerned. The person who, as a consultor, has contributed to the transfer, to the transferor, together with the transferor and the four. Act. mentioned persons and companies when the advisory worker at the time of his complicity knew or should know that the transfer would be overpried.

Paragraph 2. If the transferor is a person, the determination of paragraph 1 shall apply. ONE, ONE, THREE. points, only where the transfer relates to capital units which are taken into account in the section 4 of the asset ' s holdings of the asset ' s assets, so that a ownership share of 10% shall be applied. the share capital of the stock or the capital chapter shall be considered as the main shareholder of the stock. If the transferee is a company and so on, the provision shall apply in paragraph 1. ONE, ONE, THREE. points, only where the transfer relates to the capital shares of corporate companies, in accordance with the provisions of the undertaking. Section 4 (4) of the exchange rate law. However, 2, such as by means of an ownership share of 10%. of the share capital of each company shall be regarded as having companies which are affiliated.

Paragraph 3. The provision in paragraph 1 shall be Paragraph 1 shall also apply only when the transfer relates to the capital shares in a company which, at the time of transfer, is without economic risk in terms of commercial activity or by commercial activity in one or more of them ; subsidiaries in which the company owns at least 25%. Of the stock record.

Paragraph 4. Award from paragraph 1. 1 shall be deemed to be available when the payment of the capital shares clearly exceeds the proportion of the company ' s net worth of the transfer date.

Paragraph 5. Before a transfer of holdings in a company is carried out, a binding response may be obtained after the tax administration of the tax administration shall be provided to the extent to which a liability provided for in paragraph 1 may be drawn up. 1 will be applied. The binding response may be conditional upon the provision of whole or partial security for the payment of the taxes of any kind to the public, which is the responsibility of the company as a current or latent commitment at the time of transfer. An adviser can free himself from the liability referred to in paragraph 1. 1, final pkton, if the advisor before the transfer ensures that a binding reply is obtained. The binding reply shall be made no later than three months after the receipt of all information which has been received by customs and tax authorities, which are of relevance to the reply. In the case of the binding reply, not later than three months after the receipt of the information received by customs and tax authorities, the advice shall be exempt from the liability referred to in paragraph 1. One, last point.

Paragraph 6. Against the handover of the handover or counsel, may be liable to liability in accordance with paragraph 1. 1 shall be applied only after the Council of Skatteretre.

§ 34. In addition, the rules of taxation apply to the companies and associations, etc., in so far as they are compatible with the provisions laid down in this Act.

§ 34 A. (Aphat)

TITLE VII

Entry into force and transitional provisions

$35. 2) Taxable undertakings, etc., for each of the income years 2002 to and with the latest revenue due to expire before the time of notification, shall carry out digital reporting to the customs and tax administration of the remainder of the goods ; deficits, cf. Section 12 and the Fund for the Fund Code 3 (3). 2. for co-taxed companies, the management company shall be responsible for the obligation to notify the management company The non-reported deficit, which shall not be reported after 1. in the light of the provisions of section 12 and the Fund Taxation Act, Section 3 (3). Two, do not deduculent in the taxable income.

Paragraph 2. Tax-free restructurings covered by the fusion tax law that is significant for the application of paragraph 1. 1 and which have been completed before the time of the notification, the digital file shall be reported.

Paragraph 3. Where the accrual of the deficit is not subject to the application of the deficit, the tax minister may dispense with the obligation to report deficits for each of the income years 2002 to and with the latest revenue expires before reporting time.

Paragraph 4. The tax minister shall lay down rules on the time of reporting, the customs and administration of duties, in the event of exceptional circumstances, to disregard the period of extrancation, the period of notification, of the specifications ; the reporting shall contain and how the alert shall be carried out in accordance with paragraph 1. One and two.

§ 35 A. (Aphat)

§ 35 B. (Aphat)

§ 35 C. (Aphat)

§ 35 D. (Aphat)

§ 35 E. (Aphat)

§ 35 F. (Aphat)

§ 35 G. (Aphat)

§ 35 H. (Aphat)

§ 35 IN. (Aphat)

$35 J. (Aphat)

§ 35 K. (Aphat)

§ 35 L. For associations which, from the income of the income of the year 1994, shall be transferred to taxation on the basis of Article 1 (1) of the income year. 1, no. 3, from taxation in accordance with section 1 (1). 1, no. 6, find Section 5 A similar use, cf. however, paragraph 1 2-4.

Paragraph 2. The amount of the taxable amount shall be done in accordance with section 5 A (3). 3, resulting from profits from earnings in section 21 and the property tax tax law, shall not be included in taxation under Section 5 A (3). 1. This profit is taken first to the taxable income of that income, where the association is actually in the building, the installation or the property. Title 6 A and 6 C property shall not apply. If the association at the time of deprecation is subject to paragraph 1, paragraph 1 shall be taxed. 1, no. 3, the amount collected shall be multiplied by 2,3.

Paragraph 3. When the association is dissolved or transferred from taxation in accordance with section 1 (2), 1, no. 3, to taxation in accordance with section 1 (1). 1, no. 6, or exempted from taxation pursuant to section 3, any remaining taxable amount shall be required in accordance with paragraph 1. 2 shall be counted as to the taxable income of the association for the income in which the solution or the transition is made.

§ 35 M. The value of shares referred to in section 215 of the Act of financial activity shall be transferred to a reconciliation, not counting on the tax-free income of the association.

$35 N. (Aphat)

§ 35 O. For electricity companies (electricity heavy/s), which shall be transferred to taxation in accordance with section 1 (1). 1, no. 1 or 2 e, or § 2, cf. Section 1 (1). 1, no. 1 or 2 e, from the tax base in accordance with section 3 (3). 1, no. Paragraph 4 shall apply the transitional provisions in paragraph 1. 2-5 usage.

Paragraph 2. Machinery, equipment and other similar operating methods, as well as ships that the electric company owns prior to the transition to the taxable duty, are included in the balance value according to the rules of the purchase order, written down by the technical value degradation. Depreciation may instead be carried out on the basis of the restock value adjusted for the life cycle and adjusted for inflation / price increases.

Paragraph 3. On buildings depreciated according to the rules of the depreciation law, or on installations serving only such buildings and acquired or completed prior to the transition to the taxable duty, depreciation shall be carried out on the basis of the law of the Regulation ; value with which the building or installation is included in the property value of the rating per 1. January 2000.

Paragraph 4. In non-printing-entitled buildings, depreciation is made on depreciation warranted installations which have been acquired or completed prior to the transition to the tax base, on the basis of the value by which the installation is estimated to be included in the property value ; at the assessment per 1. January 2000.

Paragraph 5. For profit or loss on the property tax law, the tax liability law, the profit or depreciation law, section 39 or 40 shall apply to the section 35 K (1) of the company tax bill. 1-4, corresponding use when the asset or debt has been acquired, respectively, prior to the transition to the tax burden. For real property, the property value is set to the property. 1. In January 2000, instead of the values referred to in section 35 K (1), ONE, TWO, FOUR. Act.

Paragraph 6. For municipalities, from 1. In January 2000 the taxable shall be set out in accordance with Article 1 (1) 1, no. 2 f, or Section 3 (3). 7, as well as companies and associations, etc., which are transferred to taxation in accordance with section 1 (1). 1, no. 1 or 2 e, or § 2, cf. Section 1 (1). 1, no. 1 or 2 e, of revenue from the production of electricity and heat from the tax base in accordance with section 3 (3). 1, no. 5 or 6 shall apply the rules set out in paragraph 1. 1-5 use on assets and liabilities relating to this company.

Paragraph 7. Decentraal power heating system, cf. § 5, Act 5. 375 of 2. In June 1999 on the electricity supply, which is not owned by an electricity service, shall be able to write an amount equal to that part of the net power plant, set up for the exchange rate per year. the date of transition to the tax duty over 20 years from the date of the taxable entry, or deduction and indexations on the index loan before 1. In January 2000, relating to the period following the transition to the tax burden, the income of the taxable person shall be charged. The facility may then not be discharged to assets which it owns in the transition to a tax obligation, and in the subsequent abstention of such assets, the total abstention shall be taken into account, regardless of the nature of the asset, in the calculation of the income of the taxable income. In the subject of a 2-point abstention. Act. the principles set out in the property section 4 (4) of the property tax shall be subject to : 4-9, corresponding use. In the case of net debts, the proportion of the total debt of the plant, which exceeds the claims of the facility covered by the profit-making system, the securities covered by the cash tax and the cartridge shall be covered by the stock-profit system. It shall be made to indicate that the tax return for the first income is binding on the basis of the obligation to declare an amount equal to the net or deduction and indexations on index loans after 1. Act.

§ 36. (Aphat)

§ 37. (Aphat)

§ 38. (Aphat)

§ 39. (Aphat)

§ 40. The tax minister shall lay down detailed rules for the implementation of this law and shall be authorised to hold the expenditure required for the law.

§ 41. This law does not apply to the Faroe Islands and Greenland.

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. In 310, page 34, Council Directive 2011 /96/EU of 30. November 2011 on a common system of taxation for the mother and subsidiaries of various Member States, 2011 EU Official Journal (2011). L 345, page 8, Council Directive 2003 /49/EC of 3. June 2003 on a common system for the taxation of interest and royalties paid between associated companies in different Member States, EU Official Journal 2003, nr. L157, page 49, as amended by Council Directive 2004 /66/EC of 26. April 2004 adapting, inter alia, Council Directive 2003 /49/EC in the field of free movement of goods, the free movement of services, agriculture, transport policy and taxation as a result of the Czech Republic, Estonia, Cyprus, Latvia, Lithuania, Hungary, The accession of Malta, Poland, Slovenia and Slovakia, the EU-Official Journal of the European Union, no. L 168, page 35, by Council Directive 2004 /76/EC of 29. April 2004 amending Directive 2003 /49/EC in respect of the possibility of applying transitional periods for the application of a common system for the taxation of interest and royalties paid between associated companies in Member States, the EU Official Journal, 2004, nr. L157, page 106, and by Council Directive 2006 /98/EC of 20. In November 2006, concerning the adaptation of certain directives concerning taxation, due to the accession of Bulgaria and Romania, the EU-2006-2006. L-363, page 129.

2) It comes from paragraph 4 (4). Fifth Amendment No 5. 528 of 28. May 2014, that legal persons, who, on the basis of Article 4 (4) of the tax control Act, are 2, shall file the tax return for the period from 1. October to the 31. July after the end of the income year, the expiry date of the income year of the income year may expire during the period during which the report for the resulting production is to be carried out, shall wait for the income of the income to be submitted for the income of 1. August of the year after the end of the year.