Article Category: Article
Published Online: May 19, 2025
Page range: 95 - 112
Received: Jan 19, 2024
Accepted: May 03, 2024
DOI: https://doi.org/10.2478/ntaxj-2024-0003
Keywords
© 2024 Frederik Zimmer, published by Sciendo
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License.
The Norwegian dividend tax regime is uniquely characterized by the so-called shielding allowance, which implies that the shareholders are entitled to receive a nearly risk-free yield of the investment without tax, unlike the rest of the dividend. This article attempts to evaluate the arguments behind these rules. These arguments are embedded in economic theory on neutrality; in particular, the issue is to what extent the dividend tax increases the financial costs of a company. The Norwegian and international debates among economists show that the central issue today is to what extent the company’s financial cost is decided on international or domestic financial markets. In the former case, the Norwegian dividend tax does not affect the company’s financial cost. Arguments against the shielding allowance regime are also evaluated. The article ends with a brief discussion of a recent proposal to extend the shielding allowance regime to all types of capital income or to some of them.