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Taxing Dividends in a Dual Income Tax System: The Nordic Experience with the Income Splitting Rules Cover

Taxing Dividends in a Dual Income Tax System: The Nordic Experience with the Income Splitting Rules

By: Håkan Selin  
Open Access
|May 2025

Abstract

In a dual income tax (DIT) system, labor income is taxed progressively, while capital income is subject to a lower proportional tax. DIT systems were introduced in Sweden, Norway, and Finland in the early 1990s. In the absence of rules restricting capital income distributions, owners of closely held corporations would easily be able to circumvent the progressive tax on earned income by withdrawing an appropriate amount of dividends instead of wages. The Nordic countries adopted very different income splitting models, with immediate implications for the tax treatment of dividends. In this article, I first review the principles of the income splitting rules of Sweden, Norway, and Finland. I then discuss some of the trade-offs involved in the design of such rules.

Language: English
Page range: 83 - 94
Submitted on: Jan 15, 2024
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Accepted on: Nov 7, 2024
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Published on: May 19, 2025
In partnership with: Paradigm Publishing Services
Publication frequency: 1 issue per year

© 2025 Håkan Selin, published by DJØF Publishing, Nordic Tax Research Council
This work is licensed under the Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 License.