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Danish Companies in International structures St . Petersburg September 2010 Jan Breum Eriksen

Danish Companies in International structures St . Petersburg September 2010 Jan Breum Eriksen Director Group Head Quarters. Partnerships K/S. General Partner. Limited Partner. Limited Partner. Limited Partner. Danish Partnership K/S. Taxation of K/S. Transparent entity if:

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Danish Companies in International structures St . Petersburg September 2010 Jan Breum Eriksen

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  1. Danish Companies in International structures St. Petersburg September 2010 Jan Breum Eriksen Director Group Head Quarters

  2. PartnershipsK/S General Partner Limited Partner Limited Partner Limited Partner Danish Partnership K/S

  3. Taxation of K/S Transparent entity if: • More than 50% of the partners are located in the EU or in Jurisdictions where Denmark has a DTT or EIT with AND • The partner is located in a jurisdiction which recognise partnerships as transparent All other cases it is non- transparent and will be taxed in Denmark at 25%

  4. Registered vs Non-registration • K/S Registered with DCCA if the General partner is a company with capital • If the general partner is a company without capital or a physical person the company will be de-registered with DCCA

  5. Deregistered K/S • A company having been automatically de-registered does, however, still exist • If the company is de-registered it gives the client total anonymity • But is it workable????? The choice is up to the client!

  6. Simple Structure Isle of Man Cyprus SMBA

  7. Danish SMBAs • No Danish tax is payable if not managed from Denmark • Limited reporting requirements • Shareholder loans are permitted • No capital is required • No shareholders on public file • No audit requirement • Limited liability

  8. SMBA (Continued) • No Corporate Directors • No Audit requirement

  9. Reporting Requirements NO filing of accounts at the DCCA if 2 out of the 3 criteria below are fulfilled: • Less than 10 Employees • Turnover is less than DKK14 million (USD2.2m) • Balance not exceeding DKK7million • (USD 1.1m)

  10. SMBA vsApS (Limited) • Main difference: The SMBA must not distribute profits to shareholders in proportion to the shareholders capital contribution • Solution: Each shareholder receives 50% of the profits no matter what capital he has contributed with

  11. BUT Filing of Tax returns are Compulsory Also if the income is not taxable

  12. HybridSMBA Cyprus Isle of Man SMBA Guarantor member

  13. Trading Trust SMBA XYZ SMBA XYZ SMBA Isle of Man Trust ABC gmbh BCD sarl CDE Ltd

  14. CONTACT DK@Sovereigngroup.com

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