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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:   
Open Access
|May 2025

Figures & Tables

Table 1:

Summary of splitting rules in Sweden, Norway, and Finland

Sweden 1991–2005Sweden 2006-Norway 1992–2005Norway 2006–Finland 1993-
Activity requirementYesYesYesNoNo
Ownership requirementFew majority owners Active owners control > 70%Active owners control > 2/3NoNon-listed shares
Base for DAAcquisition value of sharesaFixed amount OR wage sumGross assets, wage sumbAcquisition value of sharesNet assets
Pres. rate of return (ρ)5% + risk-free (1991)9% + risk-freec (2024)4% + risk-free (2003)risk-free (2024)8% (2024)
Cap gains included in the DA?YesYesNoYesNo
Carry-forward of DA:sYesYesNoYesNo

1 Notes: The table schematically describes properties of the income splitting systems of Sweden, Norway, and Finland. Note that it is non-standard to label the Norwegian post-2006 system as a splitting system.

1a The wage sum is the dominating, but not the only source of the DA for those who choose the “main rule”.

1b The Norwegian system 1992–2005 did not include optional dividend allowances, because income splitting was made independently of the dividend decision.

1c The interest rate used to accumulate DAs, i.e. ρ˜ of equations (3) and (4), was 3% + the risk-free interest rate.

Table 2:

Current tax rates

SwedenNorwayFinland
Dividend tax, D < DA36.48 (20)22 (0)26(7.5) or 26.8(8.5) 43.12(28.9) > EUR 150,000
Dividend tax, D ≥ DA65 (55b) 44.42(30) > EUR 600,000b51.5 (37.8)54 (42)
Tax on capital gainsAlmost as dividendsAs dividendsAs capital income
Top MTR labor income66 [55b]49.5[47.4](low) 55.8[47.4](high)56 [56b]
Capital income tax rate302230 < EUR 30,000 34 ≥ EUR 30,000
Corporate tax rate20.62220

1 Notes: All tax rates are expressed in percent and refer to the tax year of 2024. Dividend tax rates include corporate tax rates. Dividend tax rates excluding corporate taxes are in parentheses. Marginal tax rates (MTR:s) on labor income include payroll taxes. Marginal tax rates excluding payroll taxes are reported in squared brackets.

1 The ceiling for dividends being taxed as labor income is 90 income base amounts.

1b Top marginal tax rate on labor income (average local tax rate) including the employee’s social security contribution in Finland.

Language: English
Page range: 83 - 94
Submitted on: Jan 15, 2024
Accepted on: Nov 7, 2024
Published on: May 19, 2025
Published by: DJØF Publishing, Nordic Tax Research Council
In partnership with: Paradigm Publishing Services
JEL:

© 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.