Most importantly, the tax reform of 2006 harmonized tax rates between capital and labor incomes by introducing a dividends tax, but the later and gradual tax changes over the years 2013 to 2019 have also caused notable changes in incentives to extract dividends from companies to private owners and for organization of private corporations.
This report provides a descriptive analysis of changes in central measures of dividends takeout and ownership structure for private companies in Norway over the period 2004 - 2018. We replicate and extend earlier analyses by Røstadsand (2008; 2008) on dividends and capital transfers between private owners and private corporations in Norway, showing that dividends were considerably higher in the years 2004-2005 and 2015 in order to extract dividends before the introduction of the dividends tax and the adjustment factor to this tax, respectively. These funds were largely loaned back to the corporations in the following years, implying considerably smaller changes in the availability of capital for the corporate sector than pure measures of dividends takeout would suggest.
Furthermore, we pierce multiple layers of ownership to these companies using detailed data on stock ownership. This allows us to construct detailed measures of ownership based on final owners and on the level of ownership. We use this to show that the overall share of ownership of Norwegian private corporations is fairly stable over the period, a fact that would be obscured by the large increase in indirect ownership that we see in official statistics. We furthermore show that dividends takeout behavior is much more sensitive to changes in dividend taxation over time for Norwegian private owners and for directly held firms, in line with what we would expect.
Finally we quantify the importance of an exception to the general principle that private firms are valued at book values for wealth tax purposes. This exception states that new firms may be valued at the sum of share capital and premiums paid in the year of establishment. New firms are valued at considerably less than book value under this exception, indicating that owners strategically organize valuable assets in new firms to minimize the wealth tax burden for their owners.