Industrial Foundations in the Tax System

Søren Bo Nielsen

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This paper attempts to place industrial foundations (IFs in the following; similar to trusts) in the tax system. An industrial foundation is a private foundation that holds a voting majority in a joint stock corporation. These IFs are probably more prevalent in Denmark than in any other country, and the paper starts by reviewing some stylized facts and figures for IFs in Denmark. Thereafter, it recalls basic desires as to the structure and logic in the tax system and demonstrates how they lead to a system akin to the ‘dual income tax’ system which has inspired tax reforms in the Nordic countries and elsewhere. This system implies clear consequences for the taxation of different types of income, labor income and capital income. However, as the outline of the system is based on the premise that “people pay taxes”, industrial foundations, having no personal owners, do not immediately fit in. So what to do? The paper explores the implications of treating IFs as high‐income earners (wealthy individuals) and draws the conclusion that in the current system, IFs are very leniently taxed relative to that benchmark. Lenient tax treatment relative to the norm is regularly interpreted as tax expenditures; the usual recommendation for such indirect subsidies is to render them direct by transferring them from the revenue to the expenditure side of the budget.
Publikationsdato18 sep. 2014
Antal sider19
StatusUdgivet - 18 sep. 2014
Begivenhed70th Annual Congress of the International Institute of Public Finance: Redesigning the Welfare State for Aging Societies - Lugano, Schweiz
Varighed: 20 aug. 201423 aug. 2014
Konferencens nummer: 70


Konference70th Annual Congress of the International Institute of Public Finance
SponsorUniversità della Svizzera italiana


  • Industrial foundations
  • Tax system
  • Capital income taxation
  • Donations