The Achilles Heel of the Dual Income Tax: The Norwegian Case

Abstract

The dual income tax provides the self-employed individual with large incentives to participate in tax minimizing income shifting. The present paper analyses the income shifting incentives under the Norwegian split model when real capital investments are risky. It concludes that high-income self-employed individuals can incorporate and use the legal form of a widely held corporation as a tax shelter. In addition, real capital investments with a low risk profile are means to shift income from the labor income tax base to the capital income tax base for the highincome self-employed.