Investeraravdraget: En ändamålsenlig lösning på den skattemässigt asymmetriska behandlingen av bolag finansierade genom eget kapital respektive lånat kapital?
Independent thesis Advanced level (degree of Master (Two Years)), 20 credits / 30 HE creditsStudent thesis
Companies financed through borrowed capital are allowed a tax deduction for the costs re-lated to their borrowed capital. A similar tax relief for companies financed through share-holder’s equity does not exist, why these companies are taxed higher than companies fi-nanced by borrowed capital. The result is that there is an asymmetric tax treatment of companies depending on how they are financed.
The autumn of 2012, the Swedish government presents a proposal for an investor deduc-tion which seeks to equalize the above mentioned asymmetry. The proposed investor de-duction is a tax relief for investments in shares in a startup- or small company equal to 50 percent of the acquisition cost of that investment.
The venture capital deduction, which in this thesis is treated as an alternative to the inves-tor deduction, is an interest-free tax credit which significate that two-thirds of the acquisi-tion cost is deductible from taxation at the time of the acquisition. Another alternative is the UK's Enterprise Investment Scheme (EIS), which offers a package of tax reliefs that becomes applicable when an individual invests in a company for example a tax credit of 30 percent of the cost of acquisition. A final option is the Notional Interest Deduction (NID) which is a tax deduction for companies regarding a fictitious interest on equity.
Of these models, only the NID deduction equalizes the tax asymmetry, because of that it is a relief that is comparable to the tax credit deduction for interest on borrowed capital. However entails all models, except the venture capital deduction, to make external capital more accessible by reducing the external investor's required rate of return by allowing a permanent tax relief. Aside from the NID deduction all models includes conditions that
reduces the risk of the use of the models for purpose of tax avoidance which results in that that models can be perceived as complex.
Place, publisher, year, edition, pages
2012. , 64 p.
Investeraravdrag, riskkapitalavdrag, Notional Investment Deduct-ion, NID, Enterpirse Investment Scheme, EIS, ändamålsenlighet, skattemässig asymmetri
IdentifiersURN: urn:nbn:se:hj:diva-20125OAI: oai:DiVA.org:hj-20125DiVA: diva2:579400
Subject / course
IHH, Commercial Law
UppsokSocial and Behavioural Science, Law