Information about tax regulations due to Transferator AB’s distribution of Mr Green & Co AB shares
The summary of tax regulations described in this information leaflet is applicable solely to the holders of Transferator AB shares who are either Swedish limited liability companies or Swedish private individuals who are solely a tax resident in Sweden at the date of the transaction. The summary is based on current Swedish tax legislation and practices at the time of the transactions and is solely intended to provide general information.
The tax implications for individual shareholders are partly dependent on the circumstances in specific cases. Consequently, every individual shareholder should consult a tax advisor concerning the tax implications of the transactions.
Transferator AB’s distribution of its shares in the subsidiary Mr Green
In 2013, Transferator AB decided to distribute all of its shares in its subsidiary Mr Green to Transferator AB’s shareholders. For every two Transferator AB shares, one Mr Green share was received.
The benefit of shareholders receiving shares in another company without payment is taxable as a dividend. This dividend is tax exempt if certain conditions are fulfilled (Lex Asea).
Transferator AB has come to the conclusion that the conditions for receiving tax-exempt dividends of Mr Green shares have been fulfilled. Accordingly, the dividends will not be subject to tax during 2013. Instead, shareholder acquisition costs for Transferator AB shares are to be distributed between Transferator AB shares and the Mr Green shares received.
The Swedish Tax Agency provides information on proportioning of acquisition costs. The Swedish Tax Agency’s general recommendations (SKV A 2014:02) state that of the acquisition cost for Transferator AB shares, regardless of share class, 9% should be attributable to these shares and 91% to the Mr Green shares received.
Example:
The acquisition cost for 100 Transferator AB shares at the time of the distribution of Mr Green shares is assumed to be SEK 50. Of this amount, 9% or SEK 4.50 (0.09 x 50) is attributed to Transferator AB shares and 91% or SEK 45.50 (0.91 x 50) is attributed to the 50 Mr Green shares received (for two Transferator AB shares, one Mr Green share is received).
We recommend that shareholders who received Mr Green shares through what is known as a Lex Asea dividend declare the dividend in their income tax return for the 2013 income year and refer to the Swedish Tax Agency’s general recommendations (SKV A 2014:02). Refer also to this link.
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