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.
Original languageEnglish
Publication date18 Sept 2014
Number of pages19
Publication statusPublished - 18 Sept 2014
Event70th Annual Congress of the International Institute of Public Finance: Redesigning the Welfare State for Aging Societies - Lugano, Switzerland
Duration: 20 Aug 201423 Aug 2014
Conference number: 70


Conference70th Annual Congress of the International Institute of Public Finance
SponsorUniversity of Lugano
Internet address


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

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