Apportionment of the tax basis in Novo Nordisk A/S shares held prior to the demerger between shares held in Novo Nordisk A/S and shares received in Novozymes A/S in connection with the demerger.
The Danish tax authorities have approved an apportionment based upon the average quotations of the new Novozymes shares and Novo Nordisk A/S shares on the Copenhagen Stock Exchange during the first twenty days following the first day of listing of Novozymes A/S shares. This corresponds to the period 17.11.2000 – 14.12.2000 – both days included.
The average price of the Novo Nordisk share in this period was 1,579.30 and 160.76 for the Novozymes share. The total value should accordingly be apportioned with 90.7% to Novo Nordisk A/S and 9.3% to Novozymes A/S.
For UK shareholders the cost will be apportioned between the Novozymes A/S shares and the new Novo Nordisk A/S shares with reference to the market value of the respective shares on the first day of trading in Novozymes A/S shares (17.11.2000). These values were 1,560.26 (90.3%)for Novo Nordisk A/S and 168.36 (9.7%) for Novozymes A/S. The GBP/DKK rate on the same day was 1,240.65.
The US shareholder’s tax basis for the shares in Novozymes A/S and shares of the new Novo Nordisk A/S after the demerger will equal the US shareholder’s tax basis in Novo Nordisk A/S before the demerger, allocated in proportion to the relative fair market value of shares in Novo Nordisk A/S and shares in Novozymes A/S.
US tax law does not prescribe a method for determining the fair market value of the Novozymes A/S shares and the Novo Nordisk A/S shares. US tax law merely provides that the basis to be allocated among the shares held immediately after the transaction in proportion is the fair market value of the stock. The above-mentioned 20 days average is merely used to provide an allocation percentage to the convenience of the US shareholders.