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169 Uppsatser om Shareholder taxation - Sida 1 av 12

Koncernbidragets hantering ur ett ABL-perspektiv: - En analys av det vedertagna tillvägagångssättet

The use of group contribution between consolidated firms is a common phenomenon in Sweden where taxation is not based on the return on the consolidated level but on the return on the individual firms. However, the process of handling the group contribution does not work without problems. This thesis analyzes three main issues where group contributions oppose the Swedish Companies Act. ? The Swedish Companies Act enacts the decision regarding group contributions to be made at a shareholder?s meeting.

Ansvarsskyldighet för aktieägare : Personligt ansvar och skadestånd

Shareholder, who decides to continue with the company, can cause that they become per-sonally liable for its upcoming obligations. Creditors must lodge an appeal against the shareholder to get compensation for the harm they have suffered. The damage rules in Swedish company law are designed to utilize the company?s interest, that is, shareholders and other corporate members shall promote the interests of the company and not cause damage.The rules about compensation that shareholder obligates itself to are difficult to apply and are adapt to the specific cases. For a shareholder to be personally responsible in a real situation a company has to establish a subsidiary company, which is being driven undercapitalized, intended to benefit the shareholder.

Beskattning av skadestånd och liknande ersättningar

The purpose of the thesis is to illustrate how payments of damages between companies are treated from a taxation point of view, and to analyse, in a tax law perspective, the consequences that follow the transactions. Furthermore, a comparison is made between damages and transactions similar to damages, such as amicable settlements and fines between companies, to ascertain whether they are treated similar. Finally, there is an analysis of the consequences of taxation of insurances, both premiums and compensations, followed by a comparison with the consequences of taxation of damages..

A Comparison of Strategic Alliances and Mergers & Acquisitions and their Impact on Shareholder Value

A comparison of strategic alliances and mergers & acquisitions and their impact on shareholder value has been done. By using an event study methodology, the announcements of these strategic approaches has been analysed in order to understand which strategic approach affect shareholder value most favourably..

Omvandling av ett villkorat aktieägartillskott till ett ovillkorat

A contribution that is to be repaid and has been made by a shareholder should be considered disposed when the receiving company is declared bankrupt. Converting such a contribution to one that is not to be repaid should mean that the contribution is disposed to its marketvalue. It is then considered that the shareholder makes a new contribution that is not to be repaid. Hereby, the shareholder will probably make a capital loss, which should be deductible..

De nya löneunderlagsreglerna : Uppfyller lagstiftaren sitt syfte

On the 1st of January 2014, new legislation was introduced on taxation of shareholders in close companies. The legislation has faced criticism from several of the respondents and the purpose of the master?s thesis is to critically examine the legislative amendments made. The base of the thesis is to present the legislation within taxation of shareholders in close companies, to examine the purposes and motives of the legislator and the criticism received for the legislative amendments, as well as provide a historical perspective of the purpose of the rules. An analysis of the incentives that the legislator is providing shareholders in close companies, with the amendments, and the extent to which they reflect the purpose of the legislation.

Shareholder value - The American way and the Swedish game to play? : En studie om ideologisk förändring i svensk bolagsstyrning

Shareholder value has its origin in the American corporate governance system and has been the subject of great debate over the last few decades. The proponents claim that it creates economic efficiency while the critics argue that maximization of shareholder value jeopardizes the long term survival of companies. However, the debate in Sweden already seems to have forgotten the question of how embedded the ideology really is and what´s leading its way. This study show that shareholder value has developed and been established in Swedish companies between 1995 and 2005. The study has found evidence that suggests that the development can primarily be linked to board networks and international exposure.

Sveriges CFC-reglering : En anpassning till EG-rätten

The Swedish CFC rules imply a taxation of Swedish partners of foreign legal persons subject to low income tax, which is based on a fictitious distribution. Thus, tax is levied even if the dividend has not been paid to the shareholder. The aim of the Swedish CFC legislation, which was put into force in 1990, was to prevent tax evasion and to protect the Swedish tax base. The reason was that the foreign exchange control was abolished, which made investments in foreign countries possible for Swedish companies. A CFC legislation was considered necessary for Sweden in order not to lose tax revenues.The legislation was strengthened on January 1st 2004 as a consequence of the abolished taxation of capital income of commercial shares.

3:12-reglerna : Tillämpning av löneunderlagsregeln

The 3:12-provisions are part of a legal system specified for owners of close corporations (companies owned and managed by a small group of businesspeople), for taxation of capi-tal gains and dividend. The reason for special rules for the taxation of these owners is to prevent them from transforming their income, to only be subject of the lower taxation of capital gains, instead of income of service. Since the rules were put in force, they have been subject to several changes. The most recent changes took effect on the 1 January 2006. They involve a higher importance for the rule of salary-based taxation.

Sambandet mellan redovisning och beskattning : Koppling eller frikoppling

Since January 1st 2005, public companies within the European Union shall prepare their consolidated accounts in conformity with the international accounting standards. The adopted accounting standards are IASB?s IAS/IFRS completed with interpretations. Furthermore, member states may permit or require public companies to prepare their annual accounts according to IAS/IFRS. Sweden has not yet given companies the ability to use IAS/IFRS in the annual accounts due to taxation difficulties the strong relationship between accounting and taxation brings.

Internprissättningsproblematiken i ljuset av förslaget om hemlandsbeskattning för europeiska koncerner

Throughout this thesis three main factors have been identified that can be out of significance for transfer pricing in multinational companies if the proposal for Home State Taxation is adopted. These factors are rules for calculation of the tax base, rules for dividing costs over periods and the tax rate. The formula for sharing profits will also become a factor that can have an impact on the European companies'incentives for transfer pricing interacting with above-mentioned factors. The effects of transfer pricing aiming at reducing the total amount of the taxation burden for a group of companies will be strongly reduced in the future if the proposal is adopted. Incentives for transfer pricing will loose importance, though not disappear altogether.

Beskattning av pokervinster

The purpose of the paper is to examine the state of law concerning taxation of Swedish poker winnings. The main findings are: Poker is seen as a random and adventurous game. Poker is thereby considered a lottery. Swedish poker winnings are thereby not taxed as income. Foreign poker winnings are taxed as income.

Private equity företagens styrning av sina portföljbolag.: Två fallstudier av relationen mellan private equity företag och portföljbolag.

The purpose of this thesis is to examine and analyze the characteristics of the management control system private equity firms use to manage their portfolio companies. The thesis takes a share holder value perspective, and it is assumed that the goal of the management control system is to increase the shareholder value in the portfolio company. In a qualitative study two private equity firms and two portfolio companies, one for each private equity firm, were studied in detail. In total, nine in debt interviews were completed. The results from this study suggest that the characteristics of the control system are dependent on the surrounding context; the focus on shareholder value and the specific characteristics of the private equity industry shape the characteristics of the management control system.

Den svenska kupongbeskattningen av utländska fondbolag och dess förenlighet med EU-rätten : Bör det svenska regelverket förändras

AbstractThe purpose of this thesis has been to investigate if the Swedish legislation concerning taxation of dividends to foreign investment funds is in violation to EU law. Furthermore, the thesis will analyze if the Fondskatteutredningens suggestions to changes in the current legislation is appropriate to the purpose it tries to obtain.Today there is a difference in the taxation of dividends paid to Swedish investment funds and foreign investment funds. Dividends paid to foreign investment funds is being taxed in accordance with the Coupon Tax Act (1970:624), in which no deduction of the tax is possible. Swedish investment funds on the other hand have the possibility to deduct as much of the received dividends that they have given in dividends to its shareholders.The difference in the taxation between investment funds because of origin has been reviewed by both Swedish court and by the European Court of Justice. It has in these cases been up to the courts to review if a difference in taxation of dividends could constitute a violation of the free movement.

Redovisningens internationalisering : Konsekvenserna av en potentiell frikoppling mellan redovisning och beskattning

Since 1928 the Swedish accounting and taxation has been closely linked by law which today as the European Union works with its harmonisation of the European accounting systems brings up difficulties. The Union strives to integrate the countries different ways of accounting in order to make it easier to use and understand foreign information. The Swedish connection between accounting and taxation means that a harmonisation would change the whole system as its known today. The purpose with this study is to examine what the link between the two means and how a decoupling would affect Swedish accounting and auditing. We also want to examine how the Swedish taxation office, who currently uses the accounting as a ground for taxation, could guarantee the quality of the declaration without a proper underpinning. The study shows that a decoupling could lead to an increase in quality on swedish accounting and that the administration would become more difficult to handle. The risk of dividend of untaxed profits is not seen as a problem in this context.

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