The Business Commitment of a Norwegian Company in Germany : An Examination from a Tax Perspective
Master thesis
Permanent lenke
http://hdl.handle.net/11250/170006Utgivelsesdato
2012Metadata
Vis full innførselSamlinger
Sammendrag
The German market is large and of great economic importance for Norway. A detailed
understanding of the German tax system and the cross-national regulations between
Germany and Norway are necessary for Norwegian companies who assess investment
projects in Germany. This thesis aims to provide this information. It may also serve as an
introduction to the topic for civil servants in the Norwegian Tax Administration who deal
with companies that have German affiliates.
The results are achieved by conducting a comparative examination of the different
investment alternatives from a tax perspective. The underlying analysis is initially defining
significant tax aspects of investment decision as a common frame of references.
Subsequently, the thesis provides an overview of the various legal forms. Given this
framework, a legal model is applied that allows the comparison of the different investment
alternatives. In this way, the tax consequences within the significant aspects are highlighted
for different investment approaches.
The findings of this analysis indicate that in case a Norwegian individual person is planning a
long-term investment in Germany and expects positive returns which shall be reinvested in
Germany, a subsidiary in form of a corporation has advantages in regard to current taxation.
If a Norwegian corporation intends to generate a capital gain through the subsequent
disposal of its German operations, the investment alternative of a corporation leads to zero
taxation. Yet, the examination shows also that the choice of the investment alternative has
in some instances no significant tax effects. Thus, also aspects other than taxation should be
considered.
This thesis provides valuable insights for the choice of an appropriate investment alternative
in Germany. However, due to the different characteristics of a Norwegian company and its
German business venture, the results are not universal applicable and should be evaluated in
consideration of the individual situation.