Chapter 1	Fusion of companies
Chapter 2	Fusion of cooperatives and so on
Chapter 3	Fusion with foreign companies
Chapter 4	Splitting
Chapter 5	Asset Transfer
Chapter 6	Other provisions

Completion of the Act on fusion, fission and the transfer of assets, etc. (Merger tax law) 1)

This shall be used to declare a merger, fission and the transfer of assets, etc. (Merger tax law), cf. Law Order no. 1120 of 14. November 2012, with the changes that are being made by Section 4 of Law No 433 of 16. May 2012, section 2 of the law. 1255 of 18. December 2012, Section 2 of Law No 1402 of 23. December 2012, Section 19 of the law. 600 of 12. June 2013, section 1 of law no. 1347 of 3. December 2013, section 1 of Law No 274 of 26. March, 2014, and section 9 of the law. 202 of 27. February 2015.

Chapter 1

Fusion of companies

§ 1. By mergers of limited liability companies, other than limited liability companies, as referred to in section 3 (3) of the company tax liability. 1, no. (19) or companies referred to in section 1 (1). 1, no. 2, on the income tax of limited liability companies, etc. (company tax law) companies have access to taxation according to the rules laid down in this chapter.

Paragraph 2. Use the companies the companies referred to in paragraph 1. Paragraph 1 shall be subject to the tax on company contestants in accordance with the provisions of sections 9 and 11.

Paragraph 3. Fusion is available when a company draws on its fortune as a whole to another company or merged with this.

§ 2. It is a condition of taxation in accordance with the rules laid down in this Act, that the company participants in the incoming company alone shall be remunanate with shares or parties in the receiving party and, where appropriate, a cash compensatory sum.

Paragraph 2. The provision in paragraph 1 shall be Paragraph 1 shall not apply to the share of the shares or parties of the incoming company which possesses the receiving company.

§ 3. (Aphat)

§ 4. (Aphat)

§ 5. The date of the merger ' s opening status of the receiving party shall be considered as fiscal for the date of the merger. It is a condition of the application of the rules of this Act, that the date of the merger is coincided with the date of the date of the receiving company ' s financial year.

Paragraph 2. Where the receiving company is already registered and the company has not driven business prior to the date of the merger and the company ' s own funds from the foundation, the undertaking has been executed as a cash-based cash institution which can be unrecovered in cash, the first financial period, notwithstanding paragraph, 1 running from the foundation when the financial period ends 12 months after the merger date and the period not exceed 18 months. It is not necessary for the merging companies to have the same tax merger date.

Paragraph 3. If the income of a company participating in the concentration shall be made according to the rules laid down in the section 31 (1) of the company tax law. 5, as a result of the concert connection, cf. the section 31 C of company tax has been discharged or established before or in connection with the merger, or the establishment of the group connection, regardless of paragraph 1, shall be used. 1 and 2 as the tax release date of the company. It is not necessary for the merging companies to have the same tax merger date.

§ 6. In cases where the merger occurs at a parent company ' s inheritance of assets and debt as a whole, the tax minister shall lay down detailed rules for the information to be communicated to the merger.

Paragraph 2. The tax minister shall, by the way, have the authority to lay down rules on which additional information should be provided by the receiving company for the use of customs and tax administration on the basis of the tax-related rate.

Paragraph 3. Information referred to in paragraph 1. 1 and 2 shall be submitted to customs and tax administration no later than 1 month after the day on which the concentration has been adopted in all merging companies. The introduction of the information provided is a condition for the applicable application of the law.

Paragraph 4. In the cases of concentrations of banks, savings banks and other boxes, they shall be submitted in paragraph 1. 1 and 2 of the information required for customs and tax administration no later than 1 month after the date of approval of the Finance Minister, pursuant to Article 204, in the Act of financial activities.

Paragraph 5. Customs and tax administration may disregard the expiry of a period of one month in paragraph 1. 3 and 4.

§ 7. In the calculation of the taxable income of the incoming company in the period from the expiry of the last per usual income and until the date of the merger, the income will be estimated for the entire duration of this period without regard to its length. However, for the period, at most, a rate corresponding to the depreciation rate for the active times in question is the proportionate share in respect of the period during which the period is one calendar year. The establishment shall take place without regard to the dissolution of the concentration, to the extent the receiving party enters the tax position of the incoming company. Expires the usual income of the incoming company before 31. In the calendar year in which the income of the income is replaced by the year of the year of the year of the year, the date of the month after the expiry date of the year, but before the end of the calendar year, shall constitute the last income from the beginning of the year and until the end of the year ; the date of the merger.

Paragraph 2. It shall be the responsibility of the recipient company to submit a tax return on the part of paragraph 1 in paragraph 1. 1 mentioned period. The recipient company shall be liable for any tax requirements and for any debit responsibilities, which, in accordance with the general rules of the tax legislation, will be able to direct to the incoming company. The recipient company shall enter into the requirements of the incoming company against the tax authorities relating to allowances, reimbursement and excess tax as referred to in the corporate tax law.

§ 8. Assets and liabilities, which are intact in the presence of the concentration, shall be treated in the calculation of the taxable income of the receiving company, as if they were acquired at the time of their arrival at the time of their arrival. company, and for the amounts of acquisition, to which they have been acquired by this company, cf. however, section 10 (1). 2. Any tax depreciation and precipitation that the incoming company has carried out shall be considered by the receiving company. Assets to be written proportionately to the incoming company, cf. corporate tax relief section 31 (1), 5 may also be written in a proportionate way in the receiving party. Urinated investment funds in the enclosed company and the deposited deposits in financial institutions shall be considered as if they were made by the receiving company in the deputies of the referers. This also applies, even though the taxation of the investment fund law is applied to income, which predates the foundation of the reception received.

Paragraph 2. Assets and liabilities acquired by the incoming company in the spectator or as a source of nutrition shall be treated by the calculation of the taxable income of the receiving company as if they were acquired by this company in the field of speculation. as part of nutrition. The fact that an asset or a passive at the merger has surpassed from the incoming company to the receiving company shall not preclude the asset or passivity of the receipt of the taxable income received by the receiving company shall be deemed to have been deemed to have been : the profession of speculative purposes or in the context of sustenance.

Paragraph 3. If the establishment of the taxable income is involved in the profit and loss of transferable securities, the securities of the securities shall be treated in the calculation of the taxable income of the receiving company, as to which profit and loss were to be carried out ; counting on the income statement of the receiving company.

Paragraph 4. In the calculation of a loss as referred to in section 5 A, the yield received by the incoming company shall be deemed to have been received by the receiving party.

Paragraph 5. The tax treatment of assets and liabilities which the receiving company has not acquired from a shooting company will not change as a result of the merger, provided that the assets and liabilities that can be demonstrated to be acquired in this, both in the case of the concentration, must be changed and the fury of the company ; the accounting records of the receiving company as set out in its tax return are shown as separate items. Otherwise, customs and tax administration shall determine whether or not they shall be applied to the relevant groups of assets and liabilities in the case of the receiving company.

Paragraph 6. In the case of the concentration in one of the companies deficit from previous years, this deficit may, irrespective of the provision made in the section 12 of corporate tax, cannot be deductible at the receiving company ' s income statement. In the field of mergers between tax companies, the deficit that has arisen while the companies have been cotaxed can be reduced. 2. Act. shall not apply where the receiving company or firm operating office of a tax-free restructuring directly or indirectly has received assets or liabilities from companies which were not part of the collection of taxation at the time, as the deficit occurred ; arose. For previous years of deficits after the end of the hydrocarbon tax, Chapters 2 and 3 of the hydrocarbon tax shall find 1. and 2. Act. equivalent use. However, the customs and tax administration may allow the deficit of a deficit from a field, cf. the section 18 of the hydrocarbons of section 18 (2). 1, from previous years in one of the undertakings, may be deductible at the receiving company ' s income statement for the field.

Paragraph 7. In a concentration, a loss may be in one of the merging companies from the merger date and to the day the concentration is adopted in all merging companies, not reduce the taxable income of the receiving company for an amount less than the positive net income of the company in addition to the income of depreciation of depreciation-justified operating methods and ships. The deficit is made before tax depreciation and depreciation. Furthermore, a deficit for the same period in one of the merging companies shall not reduce the taxable income of the receiving party, provided that or the companies concerned at the time of the adoption of the concentration in the essential part of the merger ; without 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.-3. Act. shall not apply if they are in the concentration participating undertakings which are in deficit as referred to in 1. 3. pkton, congleners from the merger date and to the day the concentration has been adopted in the merging companies referred to. As group-related companies, companies are considered to have more than 50% of the same shareholders or indirectly. of the share capital of each company, or directly or indirectly, possess more than 50%. of the voices in each company. The limit of 1. and, where the deficit cannot reduce the taxable income to a sum less than the positive net income of the company, shall not apply to deficits in companies, as referred to in the section 12 D (1) of corporate tax. 7.

Paragraph 8. In the case of the concentration in one of the companies unexploited deductible losses from previous income, this loss may, regardless of the rules laid down in section 16 C (4) of the body of the body of the body. Article 9 (8) of the Asset Taxation Code, section 9 (3). 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. The third party shall not be deductible from the receiving party.

§ 9. Equation sums covered by Section 2 (2). 1 shall be regarded as dividend if the shareholder after the restructuring owns shares and so on in one of the depositing or receiving companies or companies which are affiliated with the companies referred to in the same way, cf. The Section 2 of the equation.

§ 10. Descending and loss of shares which are cancelled by an receiving company at the merger shall not be included in the income statement if the recipient company owns 10%. or more of the capital of the shooting company.

Paragraph 2. Descending and loss of shares owned by the incoming company at the receiving party and which in the merger is annulled or become own shares in the receiving party by this company ' s inheritance of assets and liabilities from the incoming company company, do not count on the income statement, if the incoming company owns 10%. or more of the capital of the receiving company.

§ 11. Stock in the receiving party to which members receive compensation for shares in the incoming company shall be treated in the inventory of the taxable general income as obtained at the same time and for the same time ; Acquisition curriculum as the switched shares. Received shares in the receiving company shall be considered as part of the nutritional path of the company delta, provided that the shares were purchased within the framework of the stock market. The shares received in the receiving company shall be deemed to have been included in the section 18 of the Asset Taxation Act if the shares of the shares would be covered by this provision.

Paragraph 2. Where traded shares have been purchased at different times or have been acquired as part of the corporation participant ' s nutritional path, they shall be regarded as shares for the exchange of shares with a corresponding share of the shares received in the receiving end ; Company. The percentage is calculated after the exchange value of the retraded stock on the date of the merger referred to in section 5. If the shares received are connected with different rights, the calculation shall be made separately for each species of shares received.

Chapter 2

Fusion of cooperatives and so on

§ 12. The provisions of Chapter 1 except section 6 shall apply mutatis muth :

1) For the merger of cooperatives, the section 1 (1) of the corporation tax shall be subject to : 1, no. 3.

2) For the concentration of a company ' s associations and associations covered by the section 1 (1) of the corporation tax system. 1, no. 3 a and 4.

3) When one of them is in number two. 1 mentioned cooperatives are merging with a sorority or association as referred to in paragraph 1. However, 2, provided that the receiving association is covered by the section 1 (1) of the company tax havens. 1, no. Three a or four.

4) When one of them is in number two. 2 or other associations of use or associations shall merge with a subsidiary covered by the section 1 (1) of the corporation tax on Article 1 (1). 1, no. 1 or 2, and the consorority or association of the receiving service shall have all shares of the shares or parties involved in the shooting party.

Paragraph 2. A merger referred to in paragraph 1. 1, no. 3, a balance shall be made of the assets collected in the cooperative and costing of taxation on the basis of section 1 (1) of the corporation tax. 1, no. 3, or equivalent taxation. The amount shall be done as the trade value of the assets and liabilities of the cooperatives and liabilities at the time of the concentration have been deduced from any payment capital that has been paid. If the cooperatives have previously been subject to taxation in accordance with other rules in the section of corporation tax, the amount shall be discharged as the difference between the commercial value of the assets and liabilities of the cooperatives of the cooperatives and the trading value at the time of entry into the market ; Taxation tax according to section 1 (1) of the company tax havens. 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 selflessness, cf. Section 7 (2). 2.

Paragraph 3. The one under paragraph 1. 2 inventive amounts are taxable income for the receiving association. However, the taxation shall not enter until the unification of the merger, as referred to in Section 16 A of the body of the body, carries out the liquidation of winding-up rates in the calendar year in which the reconciliation is finally resolved, or pay for the acquisition of own and other cooperatits. 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 determines, to corporate companies, which the company or association does not have a determinant influence over. The first subparagraph and so on which is carried out after the concentration shall be deemed to be the first to deduct from the provisions of paragraph 1. 2 invented amounts. Taxation is taking place with the section 19 (19) of the company tax havens. 2, specified percentage.

Paragraph 4. The association shall inform the association of the part of the part of the section referred to in paragraph 1. 2 opted amounts not yet taxed in accordance with paragraph 1. 3.

Paragraph 5. In the event of a subsequent transition as referred to in section 5 A, the taxation of the following paragraph shall be subject to the termination of the tax. 2 invented amounts. However, the taxation of the remainder of the amount will be reentered in the event of a new entry, in the event of a later entry, as referred to in section 5 B (5) of the company tax. 1, a merger referred to in paragraph 1. 1, no. 3, or a conversion referred to in section 14 e.

Paragraph 6. It is the responsibility of the governing board of associations taxed in accordance with paragraph 1 (1) of the company tax. 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 ; for turnover by non-members, amounts to more than 25%. of the total turnover.

Paragraph 7. Paragraph 3, 2. -5. provisions shall not apply to the extent that a association is covered by the Danish company tax law's 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. THREE, TWO, FIVE. PC, apply for this part.

Paragraph 8. It is the responsibility of the governing board of an association which is taxed according to section 1 (1) of the company tax havens. 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. 3 or 3. 7.

§ 13. The receiving association shall be obliged to submit to customs and tax administration to the documents and so on, including the transcript of the General Assembly Protocol, expulsion the adoption of a merger, a revised version ; the accounting officer expulates all assets and liabilities stating the adjustments made by the transfer and an inventory of any payments to the Andelshaves in the depositing associations of their confinement on the andelledto, operational fondaccount and so on.

Paragraph 2. The tax minister shall, by the way, have the authority to lay down rules on the additional information relating to the concentration to be provided by the receiving Association for the purposes of customs and tax administration.

Paragraph 3. The people in paragraph 3. 1 and 2 of the said documents and information shall be submitted to customs and tax administration no later than 1 month after the day on which the concentration has been adopted in all merging associations or undertakings. The introduction of the said documents and information shall be a condition for the application of the law.

Paragraph 4. The customs and tax administration may, in exceptional circumstances, disregard the period referred to in paragraph 1. 3.

§ 14. Chapter 1 shall apply mutatis muctis in the following cases when no company is included as referred to in section 3 (3) of the company tax havens. 1, no. 19, in the merger :

1) For the fusion of austerity coffers as referred to in section 1 (1) of the company tax havens. 1, no. Two a.

2) When one of them is in number two. 1 mentioned savings boxes are merging with a limited company covered by company tax tender1, section 1 (1). 1, no. 1 authorised to operate the institution of financial institution and the receiving savings bank shall have all shares in the shooting company.

3) In the light of the concentration of andelskasser as referred to in section 1 (1) of the corporation tax rate. 1, no. Two a.

4) By mergers of the section 1 (1) of the company tax havens. 1, no. Five, taxed mutual insurance associations.

5) By mergers of the section 1 (1) of the company tax havens. 1, no. 6, taxed mutual insurance associations.

6) By mergers of the section 1 (1) of the company tax havens. 1, no. Five a, taxed investment associations.

7) In the case of concentrations of the UCITS, section 16 C UCITS referred to in paragraph 16, with minimum taxation. However, if one institution meets the conditions laid down in the shares of shares in the shares of the shares in shares and so on, then the second institution shall meet the same conditions.

8) In relation to the concentration of the section 3 (3) of the corporation tax havens. 1, no. 19, mentioned tax-free companies.

9) By mergers of the section 1 (1) of the company tax havens. 1, no. Two e, tax elaps.

10) By merger of the Municipality, cf. corporate tax havens in section 1 (1). 1, no. 5 (b) with a subsidiary covered by company tax on section 1 (1). 1, no. 1.

11) When mergers of water and waste water supply companies are covered by section 1 (1) of the company tax havens. 1, no. Two h.

12) When one of them is in number two. 4 said mutual insurance associations are merging with a subsidiary covered by the section 1 (1) of corporation tax. 1, no. 1 or 2, and the receiving mutual-insurance association shall have all shares of the shares or parties involved in the incoming company.

13) In the fusion of DSB, cf. corporate tax havens in section 1 (1). 1, no. 2 d, with an all-owned subsidiary.

14) By mergers of Naviair, cf. corporate tax havens in section 1 (1). 1, no. 2 i, with an all-owned subsidiary.

15) In accordance with the fusion of Energinet.dk, cf. corporate tax havens in section 1 (1). 1, no. 2 g, with an all-owned subsidiary.

16) By fusion of Danpilot, cf. corporate tax havens in section 1 (1). 1, no. 2 j, with an all-owned subsidiary.

§ 14 a. For the conversion of savings to limited liability companies, cf. § § 208-213, in the Act of Finance, Section 5, section 6 (4). 2-5, section 7 and 8 equivalent use.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8, shall be made to deduct in the receiving party where the assets of the savings and debt as a whole are transferred to one of the savings funds created by a company in which the savings bank owns the entire stock record.

Paragraph 3. A bottled savings reserve, as mentioned in section 211 of the Act of Financial Company, which is attributed to the receiving company, shall not be included in the inventory of the taxable income for the receiving company.

Paragraph 4. Stock in the receiving company provided by the operator under Section 207 of the Act of Finance, shall be deemed to have been acquired at the time the concentration has been adopted in all merging companies. Acquisition sum shall be used for the value of the assets deposited after deduction of the debt savings debt.

Paragraph 5. Assets received by the guarantors for the exchange of their guarantee certificates shall be deemed to have been obtained by exchange for the value of the guarantee that the guarantee is made.

Section 14 b. (Aphat)

§ 14 c. The provisions of Chapter 1 shall consider, to the extent that they are applicable, mutatis muchaea :

1) In the concentration of funds covered by the Fund Taxation Act.

2) When one of them is in number two. One of these funds mergers with a subsidiary covered by the section 1 (1) of the corporation tax. 1, no. 1 and the receiving fund shall have all shares of the shares or parties involved in the incoming company.

3) By mergers of associations covered by the Phones Taxation Act.

4) By fusion and by splitting municipal and county municipal holidays, created under holiday-above section 36 (5). 3 when the merger or division takes place in accordance with the municipal reform.

§ 14 d. In the case of reciprocal insurance associations for limited liability companies, taxation shall be subject to the rules laid down in Chapter 1, cf. paragraph 2-6.

Paragraph 2. It is a condition of the application of the rules that the assets and debts of the association shall be transferred to one of the association owned or established, and the association receives shares in the company equivalent to the value of the transferable. assets upon deduction of the debt ' s debt.

Paragraph 3. § 5, section 6, paragraph. Paraguations 2, 3 and 5, sections 7 and 8 shall apply mutatis mutations to the provisions of paragraph 5. 2.

Paragraph 4. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8 shall be transferred to deduction from the receiving party, the transfer of which shall be carried out in accordance with paragraph 1. Two, happens to one of the union set up by association, in which the association owns the entire stock record.

Paragraph 5. Stock in the receiving company which the association receives pursuant to paragraph 1. 2, shall be deemed to have been acquired at the time when the conversion has been adopted in all the companies involved, etc. as the acquisition sum is used by the value of the assets deposited after deduction of the debt ' s debt.

Paragraph 6. The rules of paragraph 1. 3-5 shall apply mutatis muted to the corresponding use of assets and debt in respect of the transformation as a whole, to a company owned 100%. in the first paragraph. 2 mentioned limited liability companies, and the transfer alone shall be paid in shares in shares.

Paragraph 7. The rules of company tax law's § 12 D, paragraph 1. Paragraph 3 shall not apply where the deficit is carried forward in accordance with paragraph 1. 4 or 6, and the change in the shareholder is related to the transformation of the shares of a reciprocal life insurance association to a non-life insurance company within the same group.

§ 14 e. In the case of conversion to limited liability companies, section 1 (1) of the company tax and shareholdings. 1, no. 3, in accordance with section 325, cf. § § 326-337, in corporation law, the provisions of section 9, section 11, section 12, section 12, shall apply. 2-4, and section 13 corresponding usage. However, stocks of stocks are not to be considered to be covered by Section 18 of the Asset Taxation Code.

§ 14. In the case of conversion to limited companies, associations and associations covered by company tax tender1, section 1 (1). 1, no. 2, 3 a and 4, in accordance with section 325, cf. Section 326-337, in corporation law, the provisions of Chapter 1 except for section 6 shall apply mutatis mutatis. Paragraph 13 shall also apply mutatis mutis.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8, shall be made to deduct in the receiving party, where the association ' s assets and debt as a whole is transferred to one of the association owned or created by the association, in which the association owns the entire share capital. It is a condition that the company has not previously been operating in a business location.

§ 14 g. In the case of conversion to limited liability company, section 1 (1) of the company tax liability. 1, no. 2 a, pursuant to section 207-209 in the Act of Financial Regulation, shall apply section 5, section 6 (4). 2-5, section 7, Clause 9, section 9, and section 11 similar use.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8, in the case of deduction of the recipient company, the assets and debt of the sands as a whole shall be transferred to one of the shareholder, owned or created, in which the sands box at the time of the transfer owns the entire share capital of the shares. It is a condition that the company has not previously been operating in a business location.

Paragraph 3. Regardless of the value of the Asset Taxation Act, a profit of shares in an agricultural box is to be matched by the value of shares in the recipient company, as provided for under Section 207, in the case of a financial undertaking, to an entrepreneur or unification, not by the establishment of the taxable general income of MEPs.

Paragraph 4. Stock in the recipient company, which the entrepreneur or association receives pursuant to section 207 of the Act of Finance, shall be deemed to have been acquired at the time when the conversion has been adopted in the last of the sands involved. The sum of the assets deposited shall be the sum of the assets deposited after deduction of the debt of the second and the total deposits of the cotils in the sands box.

§ 14 h. For the transformation of the Securities Central, cf. corporate tax havens in section 1 (1). 1, no. 2 c, for a limited liability company in accordance with Chapter 29 of the securities trading area, etc., the provisions of section 5, section 6 (4), shall apply. Articles 2, 3 and 5, section 7 and 8 equivalent use, cf. Three. Act. If the transfer takes place to several liability companies, a recipient company may take over that part of the tax depreciation of the deposited fund, depreciation, and provisions relating to the inherited assets. Section 15 (b) (b) 3, shall apply mutatis mutis.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8, to deduct in the recipient company whose assets and debt as a whole are transferred to any of the Fund owned or created, in which the fund at the time of the transfer owns the entire share capital. It is a condition that the company has not previously been operating in a business location.

Paragraph 3. A bottling fund, as mentioned in section 101, paragraph 1. 1 and 2, in the Act on securities trading, etc., which are attributed to a receiving limited company, shall not be included in the inventory of the taxable income for the receiving company.

Paragraph 4. Stock in the receiving party to which the operator receives pursuant to Article 98 (3). 1 3, or § 104, in the Act of securities trading, etc., shall be deemed to have been obtained at the time when the transformation is adopted in all the companies and funds, etc. As an acquisition sum, the tax value of the assets and liabilities concerned is used. The tax value of the deposited assets shall be made in accordance with the rules in section 4 (1). 2 and 4, in the area of tax-free enterprise-forming.

Section 14 of. For the conversion of electricity companies, the section 1 (1) of the company tax shall be subject to the conversion of electricity. 1, no. 2 e, for limited liability companies, shall apply mutatis mueses to the provisions of Chapter 1. Paragraph 13 shall also apply mutatis mutis.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducted from the receiving company ' s income balance according to section 12, if the company ' s assets and debt as a whole is transferred to an electrical company owned or created, in which the electrical company owns the entire share capital. It is a condition that the company has not previously been operating in a business location.

§ 14 j. For the conversion of the Post Denmark, which is covered by the section 1 (1) of the corporate tax system. 1, no. 2 b, to limited liability company, cf. The provisions of Chapter 1 apply mutatis mut////////////

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be reduced to the income from the stock company ' s income tax from section 12, and losses from previous income may notwithstanding section 8 (4). 8, shall be made to deduction in the stock company.

Section 14. In the transformation of the Danish Ship's Shipcredit Fund, cf. corporate tax havens in section 1 (1). 1, no. 5 (b) to the limited liability company in accordance with the law of a ship ' s financial institution, the provisions of section 5, section 6 (4), shall apply. 2, 3 and 5, section 7 and 8 equivalent use.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, shall be deducting from the receiving company ' s income balance according to section 12, and the loss of previous revenue losses may notwithstanding section 8 (2). 8, shall be made to deduct in the receiving company whose assets and debt as a whole are transferred to a company which has not previously run commercial activities.

Paragraph 3. A bottling fund, as mentioned in section 7 (2). 1, in the Act of a Shipping Financial Institute, which is attributed to a receiving company, shall not be included in the inventory of the taxable income for the receiving company.

Paragraph 4. Stock in the receiving party to which the operator receives the Fund in accordance with section 7 (4). 1, in the Act of a Shipping Financial Institute, shall be deemed to have been obtained at the time when the transformation has been adopted in Denmark's Shipcredit Fund and the receiving company. The fiscal value of the assets and liabilities shall be used as an acquisition sum in accordance with the rules laid down in section 4 (4). 2-4, in the low-income tax-free enterprise.

§ 14 l. In the conversion of water supply companies, the supply companies respectively, respectively, shall be covered by company tax havens in section 1 (1). 1, no. 2 h, for limited liability companies, shall apply mutatis mueses to the provisions of Chapter 1. Paragraph 13 shall also apply mutatis mutis.

Paragraph 2. Deposits from previous income may, however, Article 8 (5), may be : 6, be deducted from the receiving company ' s income balance after company tax and in the event of the undertaking ' s assets and debt as a whole to be transferred to one of the utilities owned or created, in which the supply company, owns the entire stock record. It is a condition that the company has not previously been operating in a business location.

Chapter 3

Fusion with foreign companies

§ 15. In the case of merger between a company belonging to this country and a company belonging abroad, and by merger between companies belonging abroad, companies have access to taxation in accordance with the rules laid down in paragraph 1. 2-4.

Paragraph 2. Where an overseas company, anpartcompany or company covered by the concept of company in a Member State in Article 3 of Directive 2009 /133/EC and not on taxation in this country is considered to be a transparent unit shall be deemed to be a transparent unit, by fusion, in Chapter 1, the rules laid down in Chapter 1 shall apply mutatis mues; § 8 (3) However, 1-4, they shall apply only to the assets and liabilities of the depositing company and so on which, as a result of the merger, are associated with a reception company that is indigenous. Descendants and losses on other assets and liabilities shall be taxed in accordance with the rules laid down in the section 7 of corporate tax. The assets and liabilities of the depositing company and the passives that are assigned to the permanent farm of the receiving company abroad and which are not already covered by the Danish tax will be deemed to be the taxable income of the receiving company ; here in the country for acquiring the section 4 A (3) of the company tax havens. 1 and 2, and § 8 B specified acquisition sums and acquisition times.

Paragraph 3. belong to a party belonging to a company in the presence of a company belonging to a company belonging to a company, and is the presence of the company in a Member State in accordance with Article 3 of Directive 90 /434/EEC and not by means of the receiving company, and not by the presence of the company receiving the company, the level of taxation in this country shall be regarded as transparent, in accordance with Chapter 1. § 8 (3) However, 1-4, they shall apply only to the assets and liabilities of the depositing company and so on which, as a result of the merger, are linked to the permanent operating premises of the foreign recipient company or the property in this country. Descendants and losses on other assets and liabilities shall be taxed in accordance with the rules laid down in the section 7 of corporate tax.

Paragraph 4. Where an existing company is to be established by a merger with a foreign company, and is both the incoming company subject to the concept of company in a Member State in Article 3 of Directive 2009 /133/EC and not on the taxation of this country, for a transparent unit, the rules laid down in Chapter 1 apply mutatis muters. § 8 (3) However, 1-4 shall apply only to the assets and liabilities of the depositing company and so on, which, as a result of the merger, are linked to the flat-rate operating premises or property of the receiving company here in the country. Descendants and losses on other assets and liabilities shall be taxed in accordance with the rules laid down in the section 5 of corporation tax. No matter what. Act. shall be taxed by the cancellation of shares in the holding company which is being cancelled by a consignifying company at the concentration, which shall yield on the basis of which the recipient company owns at least 10%. in the case of share capital of the incoming company, and where profit tax is not to be dropped or reduced in accordance with the provisions of Directive 2011 /96/EU on a common taxation system for the mother and daughter of the mother and subsidiaries of different Member States, or after a double-tax agreement with the Faroe Islands, Greenland or the State where the parent company is native. Similarly, the charges shall be taxed by the cancellation of shares in the incoming company which is being cancelled by a company receiving company in the case referred to in Section 16 A (1) of the body of the body. 3, no. 1 (b) and in the case where the shares of the receiving company in the incoming company are subject to the definition of tax-free portfolios in the section 4 C of the Asset Taxation Act, whether or not 1. 3. Act. a condition for the application of the rules laid down in Chapter 1 that authorization from customs and tax administration shall be authorised if a person or company which determines the influence of the incoming company in accordance with the rules of the administration. the section 2 of the body of the body and which is not covered by 4. or 5. in the case of a non-resident in EU/EEA or in a State which has a double tax agreement with Denmark. The customs and tax authorities may fix special conditions for the authorisation.

Paragraph 5. Paraguations 3 and 4 shall apply mutatis mucous, if the incoming or receiving company or both companies are resident in EU/EEA, registered in a Member State of the EEA and not a member of the European Union, is a party which corresponds to one of the other parties ; the Danish shares of Danish shares, and the competent authority of the State in which the company is indigenous, shall exchange information with the Danish authorities following a double-tax agreement, another international agreement or convention ; or an administrative agreement on assistance in tax matters.

Paragraph 6. Discover in cases other than those referred to in paragraph 1. Section 9 and 11 shall apply mutatis mucous to a company at the concentration of a company in the case of companies, including sections 9 and 11 shall apply mutatis mucous to the company concurrent. The incoming company is taxed in accordance with the rules of section 5 of corporate tax. The shareholders of the incoming company shall be taxed in the cases referred to in section 16 A (1) of the body of the body. 3, no. 1, and in the cases where the shares in the incoming company are subject to the definition of tax-free portfolios in the section 4 C of the Asset Taxation Act, section 4 of the equipment at the termination of the incoming company as a profit.

Paragraph 7. sections 9 and 11 shall apply by analogous to the concentration of companies or associations which are all non-resident abroad, if companies are not subject to the rules laid down in paragraph 1. 3.

Chapter 4

Splitting

§ 15 a. For the division of a company, companies have access to taxation in accordance with the rules in section 15 b (s). In Article 3 of Directive 2009 /133/EC and not on taxation in this country, both the incoming company and the receiving company shall be subject to the concept of company in a Member State in accordance with Article 3 of Directive 2009 /133/EC and not in the case of taxation in this country. It is a condition for the application of the authorisation from customs and tax administration. The customs and tax administration may lay down specific conditions for the authorisation and may prescribe that documents are specifically drawn up to be submitted within the time limits referred to in section 6 (2). Article 6 (3) or Section 6 (3). In the first paragraph of the year, the companies referred to in 1 of the company are being split. Act. access to taxation in accordance with the rules laid down in section 15 b (b) ; 1 and 2 without authorization from customs and tax administration, cf. -10. Act. The use of 4. Act. shall be subject to the fact that companies which, after the division of the spelling, own at least 10%. of the capital or shares covered by the definition of tax-free portfolios of the asset ' s section 4 C of one of the participating undertakings, shall not be devoting shares in the company or undertakings concerned for a period of three years after adoption ; of the division. Whatever 5. Act. the shares of a participating undertaking in the period referred to in the said period shall be assisted in the case of a tax-free restructuring of the company participant or the participating undertaking concerned if, during the restructuring, non-remuneration is not made by other than : stock. In such cases it shall be found in 5. Act. the conditions laid down in its remaining duration shall apply to the company participant or to the participating undertakings of the subsequent tax-free restructuring. 4. Act. shall not apply where the incoming company has more than one company participant and one or more of these have been members of company contestants for less than three years without the Council of the majority voting and, at the same time, or at the same time, or at the time of the division ; company participants in the receiving company where they have a majority of the votes in the consignots. 4. Act. shall also not apply to split covered by paragraph 1. 3 if a corporation participant taxed by the shares of the shareholders of the entry into section 17 of the Asset Taxation Act, which may at the same time receive tax-free benefit from these shares, shall be paid with other than shares of the holding or receiving companies. 4. Act. shall not apply either if a person or company which determines the influence of the incoming company, cf. The section 2 of the body of the body is neither resident in EU/EEA or in a State which has a double taxation agreement with Denmark.

Paragraph 2. ' split ` shall mean the transaction whereby a company transfers part of or all its assets and liabilities to one or more existing or new companies in the same conditions as to which hitherto to award its shareholders shares or the parties and, where appropriate, a cash compensatory sum. This is a condition for the application of paragraph 1. ONE, FOUR. point that the value of the shares or parties awarded with an addition to any cash compensatory sum corresponds to the commercial value of the assets and liabilities transferred. It is also a condition for the application of paragraph 1. ONE, FOUR. point, that the relationship between assets and obligations transferred to the receiving company corresponds to the relationship between assets and obligations in the incoming company. This is, at last, a condition for the application of paragraph 1. ONE, FOUR. a point that no account shall be given to companies which have at least 10% of the spaltine. of the capital of the incoming company, or whose shares in the incoming company are subject to the definition of corporate assets in the section 4 B of the Asset Taxation Act, section 4 B or the definition of tax-free portfolios of the asset ' s asset tax law § 4 C.

Paragraph 3. If the incoming company is not subject to a split, the assets and liabilities transmitted to the receiving company or to each of the receiving companies shall constitute a branch of a business, cf. § 15 c (3) (c) 2.

Paragraph 4. The provisions of this chapter shall apply mutatis muters :

1) By division of the section 1 (1) of the company tax havens. 1, no. However, 5 a, taxed investment associations, subject to the taxing or investment associations being taxed in accordance with the section 1 (1) of the company tax havens. 1, no. Five a.

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

3) By splitting the section 3 (3) of the company tax havens. 1, no. However, 19, the tax-free investment firm referred to in paragraph 3 (3) of the company tax and receiving undertakings shall be subject to the fact that it or the receiving undertakings are covered by the receiving undertakings. 1, no. 19.

Paragraph 5. The provisions of this Chapter shall apply mutatis mums to the provisions of section 1 (1) of the company tax havens. 1, no. ECU 2 e, subject to the taxing of companies, subject to the taxing or receiving companies, as provided for in section 1 (1) of the corporation tax. 1, no. Paragraph 1, or Section 1 (1). 1, no. Two e.

Paragraph 6. The provisions of this Chapter shall apply by analoging to a division of water and waste water supply companies covered by the Danish company tax law. 1, no. 2 h, if the recipient companies are taxed according to the section 1 (1) of the company tax havens. 1, no. Paragraph 1, or Section 1 (1). 1, no. Two h.

Paragraph 7. Paragraph 1 shall apply mutatis mueses if the incoming or recipient company or both companies are registered in the EU/EEA, registered in a Member State of the EEA and not a member of the European Union, is a party corresponding to a Danish ; share shares, and the competent authority of the State in which the company is indigenous, shall exchange information with the Danish authorities following a double-tax agreement, another international agreement or convention, or an administrative agreement on assistance in tax matters.

Paragraph 8. At the same time, at the same time, when the tax return on the income tax is lodged, where a split in accordance with the rules laid down in paragraph 1 ONE, FOUR. point (s) shall be carried out by the receiving company giving customs and tax management information that the company has participated in a split without authorisation from customs and tax administration. If the shares of one of the undertakings concerned as referred to in paragraph 1 shall be allegedly reapated. ONE, FIVE. ..............

§ 15 b. Spaltes a party belonging abroad, section 5, section 6, paragraph 6. 2, 3 and 5, equivalent use. Section 7 (2). Paragraph 10 shall also apply mutatis mutinis if the foreign company ceasing at the spelling of the division. If the foreign company is not subject to the division, profit or loss shall be made of the assets and liabilities of the depositing company, which are linked to a party receiving company or abroad, due to the assets and liabilities of the depositing company, or the fixed operating premises of the receiving company or the property in this country, not in the taxable income of the depositing company. § 8 (3) However, 1-4 shall apply only to the assets and liabilities of the depositing company and so on, which, as a result of the division, is linked to a company receiving company or to an abroad receiving company receiving company ' s permanent operating premises ; or real estate in this country. A recipient company may take over the part of the fiscal depreciation of the depositing company, depreciation, and provisions relating to the inherited assets. Security Fund provision as referred to in section 13 C (3) of the corporation tax system. 1, distributed as a basis for the relationship between the transfer of insurance and the total insurance stock at the time of the split. Customs and tax administration may fix a different distribution. Unused investment funds in the enclosed company and the associated deposits in the financial institutions may be transferred to one or more of the receiving companies. Raising the incoming company, taxing profits and losses on other assets and liabilities according to the rules of the section 7 of corporation tax. The assets and liabilities of the depositing company and the passives that are assigned to the permanent farm of the receiving company abroad and which are not already covered by the Danish tax will be deemed to be the taxable income of the receiving company ; here in the country for acquiring the section 4 A (3) of the company tax havens. 1 and 2, and § 8 B specified acquisition sums and acquisition times.

Paragraph 2. Spaltes a company from here in the country, section 5, section 6, paragraph 6. 2, 3 and 5, equivalent use. Section 7 (2). Paragraph 10 shall also apply mutatis mutinis if the party ceasing at the division of the woodwork. If the company is not at the division of the division, a profit or loss shall be made of the assets and liabilities of the depositing company which, as a result of the spaltine, are linked to a receiving party or a receiving party from the receiving party. company's permanent operating premises or real estate in this country, not in the taxable income of the deposits. § 8 (3) However, 1-4 shall apply only to the assets and liabilities of the depositing company and so on, which, as a result of the division, is linked to one in this country, receiving company or abroad receiving company receptive company, operating premises or real estate in this country. A recipient company may take over the part of the fiscal depreciation of the depositing company, depreciation, and provisions relating to the inherited assets. Security Fund provision as referred to in section 13 C (3) of the corporation tax system. 1, distributed as a basis for the relationship between the transfer of insurance and the total insurance stock at the time of the split. Customs and tax administration may fix a different distribution. Unused investment funds in the enclosed company and the associated deposits in the financial institutions may be transferred to one or more of the receiving companies. Raising the incoming company, taxable profits or losses on other assets and liabilities according to the rules of section 5 of corporation tax.

Paragraph 3. If the incoming company is involved, it shall be the responsibility of the receiving companies to submit a tax return on the time from the expiry of the last per usual income and until the date of the date. The recipient undertakings shall be liable for any tax claims and for any debit responsibilities, which, in accordance with the provisions of the tax legislation, will be able to direct to the incoming company. If the incoming company is involved, the receiving companies shall enter into the requirements of the incoming company against the tax authorities relating to allowances, reimbursement and excess tax as referred to in the corporate tax law.

Paragraph 4. Spalted a company and taxed the companies in accordance with the rules laid down in paragraph 1. 1 or 2, the taxing of members of companies in the incoming company shall be subject to the rules of 2. 12. Act. For the purposes of applying the rules, the date of entry shall be used for the shooting party if the company and the receiving company or the receiving companies do not have the same column of spelling. Section 9 shall apply mutatis muth. The shares of the incoming undertaking shall be deemed to have been replaced by shares in the recipient companies according to the ratio of the shares in each of the receiving companies and the total exchange value of the shares of the receiving companies ; the date of the date. If the incoming company is to be included, section 11 shall apply mutatis muthisis to the shares in each receiving company. If the incoming company does not include the division, its participants shall be deemed to have acquired shares in the receiving party or the receiving company at the same time as the shares in the company being depositing. The purchase price prior to the division of shares in the depositing company shall be distributed as an equivalence sum for the shares of the depositing company after the division and the receiving companies after the relationship between the equivalence of the shares of the stock ; the company, and each of the receiving companies, and the total exchange value of the shares of the incoming company and the receiving companies on the date of the spelling date. If the shares in the incoming company are acquired as part of the company ' s nutritional path, the shares in the receiving company or the receiving companies shall also be regarded as part of this. Where the shares in the incoming company are subject to the section 18 of the Asset Taxation Act, the shares in that or receiving company shall also be considered to be subject to those provisions. If the shares in the incoming company do not have the same fiscal status or are acquired at different times, a proportional distribution shall be made for the shares in the receiving company or the receiving companies. The proportionate units shall be calculated according to the equivallment of the stock in the incoming company on the date of the date. If the shares received are connected with different rights, the calculation shall be made separately for each species of shares received.

Paragraph 5. In the case of the submission of tax return on the income in which the division takes place, members of the party consenting to the depositing company shall make up the sum of the shares of the shares in the beneficiary or the receiving undertakings. 4. Customs and tax administration shall make the purchase of the purchase of the purchase price.

Paragraph 6. The provisions of paragraph 1. 4, 2. -14. provisions may be used accordingly when a company belonging to the parties abroad is not subject to the rules referred to in paragraph 1. 1.

Chapter 5

Asset Transfer

§ 15 c. In the case of assets of assets, companies have access to taxation in accordance with the rules in section 15 d, when both the incoming company is covered by the concept of company in a Member State in Article 3 of Directive 2009 /133/EC, and not by the taxation in this country shall be considered to be a transparent unit. It is a condition for the application of the authorisation from customs and tax administration. The customs and tax administration may lay down specific conditions for the authorisation and may prescribe that documents are specifically drawn up to be submitted within the time limits referred to in section 6 (2). Article 6 (3) or Section 6 (3). In the first point, on the supply of assets, the companies have mentioned in 1. Act. access to taxation in accordance with the rules laid down in section 15 d, without authorization from customs and tax administration, cf. Five, seven. Act. The use of 4. Act. is conditional on the non-issuing company in the receiving company for a period of three years after the introduction of the entry. Whatever 5. Act. the shares of the receiving company within the said period shall be assisted in the case of a tax-free restructuring of the incoming or receptive company, provided that the restructuring does not take place with anything other than stock. In such cases it shall be found in 5. Act. the conditions laid down in its remaining duration shall apply to the company participant or to the participating undertakings of the subsequent tax-free restructuring.

Paragraph 2. " Assets " means the transaction whereby a company without disbanding the aggregate or one or more branches of his company to another undertaking to be awarded shares or parties to the capital of the receiving company. For the purposes of a branch of a company, all assets and liabilities in a department of a company which, from an organizational point of view, constitute an independent holding, i.e. a unified unit capable of operating by means of its own resources.

Paragraph 3. The provisions of this Chapter shall apply by analogs to the transfer of assets carried out by the DSB, cf. corporate tax havens in section 1 (1). 1, no. However, 2 d, provided that the recipient company is taxed in accordance with section 1 (1) of the company tax havens. 1, no. 1.

Paragraph 4. The provisions of this Chapter shall apply by analogs to the supply of assets made under the section 1 (1) of the company tax havens. 1, no. 2 e and 2 f, and section 3 (3). 7, taxed electricity companies and so on, provided that the recipient company is taxed according to section 1 (1) of the company tax havens. 1, no. Paragraph 1, or Section 1 (1). 1, no. Two e.

Paragraph 5. The provisions of this Chapter shall apply mutatis mutias to water and sewage companies covered by company tax rules in section 1 (1). 1, no. 2 h, if the recipient company is taxed according to section 1 (1) of the company tax havens. 1, no. Paragraph 1, or Section 1 (1). 1, no. Two h.

Paragraph 6. The provisions of this Chapter shall apply by analogs to the transfer of assets carried out by Naviair, cf. corporate tax havens in section 1 (1). 1, no. Article 2 (2), provided that the recipient company is taxed in accordance with section 1 (1) of the company tax havens. 1, no. 1.

Paragraph 7. The provisions of this Chapter shall apply by analogs to the use of a company ' s corporate tax rep. 1, no. 3 a if the receiving company is taxed in accordance with section 1 (1) of the company tax havens. 1, no. Paragraph 1, or Section 1 (1). 1, no. Three a.

Paragraph 8. The provisions of this Chapter shall apply by analoging to the transfer of assets carried out by Energinet.dk, cf. corporate tax havens in section 1 (1). 1, no. 2 g, however, provided that the recipient company is taxed in accordance with section 1 (1) of the company tax havens. 1, no. 1.

Niner. 9. Paragraph 1 shall apply mutatis mueses if the incoming or recipient company or both companies are registered in the EU/EEA, registered in a Member State of the EEA and not a member of the European Union, is a party corresponding to a Danish ; share shares, and the competent authority of the State in which the company is indigenous, shall exchange information with the Danish authorities following a double-tax agreement, another international agreement or convention, or an administrative agreement on assistance in tax matters.

Paragraph 10. The provisions of this Chapter shall apply by analogi; to the transfer of assets carried out by Danpilot, cf. corporate tax havens in section 1 (1). 1, no. Article 2 (d), provided that the recipient company is taxed in accordance with section 1 (1) of the company tax havens. 1, no. 1.

Paragraph 11. At the same time, at the same time, with the submission of the tax return on the income, where the supply of assets in accordance with the rules laid down in paragraph 1. ONE, FOUR. point (s) shall be carried out by means of the recipient company giving customs and tax management information that the company has participated in a transfer of assets without authorisation from customs and tax administration. If the incoming company shares the shares referred to in paragraph 1. ONE, FIVE. ..............

§ 15 d. In the case of assets of assets, profits or losses shall be made by the assets and liabilities of the depositing company, which are linked to a receiving party to a receiving party or to an abroad receiving company receiving company, or fixed operating premises or real estate in this country, not in the taxable income of the deposits.

Paragraph 2. For the transfer of assets from one of these premises, section 5, section 6 (4), is 6.5. Articles 2, 3 and 5, and 8 equivalent use. § 8 (3) 1 4, however, it shall be applicable only to the assets and liabilities of the depositing company and so on which, as a result of the flow, is linked to a receiving party to a receiving party or to the fixed operating premises of a resident receiving company, or real estate in this country. The recipient company alone may take over the part of the tax return of tax deposits, depreciation and referenda, relating to the company ' s or the undertakings concerned. Security Fund provision as referred to in section 13 C (3) of the corporation tax system. 1, distributed as a basis for the relationship between the transfer of insurance and the total insurance cover at the time of the import. Customs and tax administration may fix a different distribution. Unused investment fund provision and the associated deposits in financial institutions may be transferred in whole or in part to a receiving party. Only a portion of the provisions shall be considered to be considered for transfer to the recipient or receiving companies.

Paragraph 3. In the case of the transfer of assets from an overseas company, section 5, section 6 (4) shall be found. Articles 2, 3 and 5, and 8 equivalent use. § 8 (3) 1 4, however, it shall be applicable only to the assets and liabilities of the depositing company and so on which, as a result of the flow, is linked to a receiving party to a receiving party or to the fixed operating premises of a resident receiving company, or real estate in this country. The recipient company alone may take over the part of the tax return of tax deposits, depreciation and referenda, relating to the company ' s or the undertakings concerned. Security Fund provision as referred to in section 13 C (3) of the corporation tax system. 1, distributed as a basis for the relationship between the transfer of insurance and the total insurance cover at the time of the import. Customs and tax administration may fix a different distribution. Unused investment fund provision and the associated deposits in financial institutions may be transferred in whole or in part to a receiving party. Only a portion of the provisions shall be considered to be considered for transfer to the recipient or receiving companies. The assets and liabilities of the depositing company and the passives that are assigned to the permanent farm of the receiving company abroad and which are not already covered by the Danish tax will be deemed to be the taxable income of the receiving company ; here in the country for acquiring the section 4 A (3) of the company tax havens. 1 and 2, and § 8 B specified acquisition sums and acquisition times.

Paragraph 4. Stock in the receiving party to which the incoming company receives in connection with the importation shall be considered to have been acquired for an amount corresponding to the value of the assets and liabilities of the assets and liabilities.

Chapter 6

Other provisions

§ 15 e. (Aphat)

§ 16. The law shall apply to mergers that are carried out on 1. January 1976 or later.

§ 17. The 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. L 310, page 34, with subsequent changes.