Abstract
This study explores empirically how business owners respond to dividend taxes in a range of different margins including tax planning and investment. Using administrative tax data on all privately held Finnish corporations, I find exceptionally clear dividend payment responses to tax rate discontinuities and changes. Studying the income composition of owners around tax changes reveals clear income shifting between wage and dividends with negligible effect on gross income received from the firm. Evidence on the asset composition of firms indicates that a notable part of the payment response is due to inter-temporal income-smoothing, while I observe no statistically significant real responses in output or investment. Heterogeneity analysis suggests that more experienced owners and owners with lower income have higher tax base elasticities.
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Notes
E.g. Acemoglu (2009)
For example, the marginal tax rate on dividends (including corporate taxes) jumped from 28 to 40.5% at 90,000 EUR between 2006 and 2011.
Auerbach (1979).
For example, Zodrow (1991) describes the capitalization mechanism in more detail.
Dividends signal the true value of the firm, and retaining earnings leaves more cash under the control of managerial choices, and thereby disincentivizes the close monitoring of managers, potentially leading to unproductive investments using retained earnings.
Dividends from publicly traded firms face a different dividend tax scheme.
The Finnish dividend tax system varies depending on the organizational form of the company. In this study, I focus on privately held corporations that are limited companies owned by a single person or a group of individuals. The privately held corporation is the most common corporate form in Finland, covering nearly half of all firms.
For example in 2008 the highest earned income tax rate kicked in at 62,000 EUR.
0.26 + (1\(-\) 0.26)*0.7*0.3. Above the monetary threshold the capital tax rate has been applied to 85% of excess dividends since 2014, and before 2014 to 70%.
It is usually optimal to pay wages until the marginal tax reaches the level of the dividend tax. The optimal low amount of wage depends on the particular year and municipality (more detail in the Appendix) as well as the amount of dividend, but the tax rate was always lower for wages than for dividends for wage income of below 20,000–25,000 EUR at the time.
Table 15 in the Appendix describes the pooled data covering all years in the panel.
The owner can postpone redeeming dividends from the firm. Thus, the dividend tax is paid according to the tax rate of the year when the dividend is redeemed, not based on the year of distribution of dividend. Therefore, some of the owners have several dividend observations for the same company and year. By way of a solution, dividend observations for an owner-company pair in a single year have been aggregated.
Kleven (2016) provides a review of the method and its indications.
Kleven (2016) provides a good introduction to bunching and how frictions and tax planning limit the use of the bunching elasticity as a structural parameter to estimate the effects of policies.
The exact limit used is 666,666.667 EUR.
Owners who were already paying capital income dividends above 90,000 EUR and thus had net assets in the firm higher than 1 M EUR did not face a change in the marginal tax rate but only in the average tax rate.
Hence the data are a balanced panel based on the 2011 net asset position.
Owners with a net asset share above 1,875,000 EUR already faced the higher capital income tax bracket, so they were likely only to face a change in their average dividend tax rate and not in the marginal tax rate.
See more in Appendix A.1.
For firms of this size, it is common that the owner also works in the firm.
However, more than 60% of the treated firms did pay dividends between 60,000 and 90,000 EUR (Table 5).
Furthermore, potential losses may further reduce the tax on capital gains at the firm level.
Shown in Fig. 14 in the Appendix.
The set-up only studies local effects of changes in the current marginal tax rate, so I cannot rule out global effects caused by changes in average tax rates or indirect effects, e.g. through the future tax burden.
The data include information on firm-owner pairs starting in 1998, and the main dataset I use starts only in 2006, allowing me to split the data by the median years as owner of the particular firm.
16.255 (0.475), 16.138 (0.496) and 15.624 (0.437) for the 9% threshold and 14.384 (0.942), 14.489 (0.790) and 13.988 (0.623) for the 8% threshold.
Employer’s social contributions (työnantajan sairausvakuutusmaksu, työeläkevakuutusmaksu, työttömyysvakuutusmaksu, ryhmähenkivakuutusmaksu) and employee’s social contributions (työeläkevakuutusmaksu, työttömyysvakuutusmaksu, vakuutetun sairausvakuutusmaksu).
This so-called YEL system, where the entrepreneur sets the labor income level, applies to all self-employed persons who are taxed according to the self employed person’s pension act, implying business owners who, alone or together with family members, own at least 50% of their firm or hold a leading position in the firm and own over 30% of the company’s shares. These are the majority of the owners studied in this essay.
Kleven (2016) provides a review of the method and its indications.
A threshold in the dividend tax schedule creates a kink point in the budget set of received income net of taxes with different amounts of gross dividends.
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Aliisa Koivisto wrote the manuscript text and prepared the empirical analysis including tables and figures.
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This study has been previously circulated under the name Dividend tax thresholds and extreme bunching. I thank Kristoffer Berg, Elias Einiö, Jarkko Harju, Markus Jäntti, Seppo Kari, Tuomas Kosonen, Kaisa Kotakorpi, Tuomas Matikka, Annika Nivala, Jukka Pirttilä, Terhi Ravaska, Tuukka Saarimaa, Håkan Selin, and numerous conference participants for their helpful comments. I gratefully acknowledge funding from the Nordic Tax Research Council, the Yrjö Jahnsson Foundation, Suomen Arvopaperimarkkinoiden Edistämissäätiö and the Academy of Finland (grant No. 346,253).
Appendix
Appendix
1.1 Additional details of the institutions and data
Earned income taxation in Finland includes a progressive government tax, a flat municipal income tax, and pension and social security contributions. Both government and municipal taxes include deductions for low-income individuals, making the effective tax schedule very progressive, with the lowest tax rates approximately zero and the highest around 55%, excluding the payroll tax paid by the employer. In calculating the marginal tax rate on earned income, I calculate the tax rate for one extra euro of the particular income type. I exclude the payroll taxFootnote 31, since for most business owners the payroll contribution is not defined by the wage sum, but is based on the so-called entrepreneur’s labor income, which is largely decided by the ownerFootnote 32. Thus the marginal payroll tax of a business owner is generally not affected by an additional euro of gross income.
The earned income tax rate applied above the net asset threshold varies depending on the taxpayer’s income and municipality. Both the municipal and government tax schedules change nearly every year. The lowest government tax rate has been zero over the whole period and, with deductions in the municipal tax for low-income earners, the aggregate earned income tax rate has also been close to zero at the low end of the income distribution. The highest overall marginal earned income tax rate has been around 55%. The government tax rates on earned income decreased over the research period of 2006–2016, especially for low- and middle-income earners. However, municipal income tax has increased; in 2000, the average rate was 17.7%, but in 2015 it was 19.9%. The municipal income tax varies across municipalities; in 2015 it ranged from 16.5% to 22.5%. Figure 11 plots the average threshold created by the net asset threshold. As the tax rate above the threshold depends on the taxpayer’s other income, the tax rates above the threshold in the figure are calculated as an average of the marginal tax rates of firm owners in each bin.
Figure 12 visualizes the thresholds in marginal tax rates. It is three-dimensional to reflect the fact that the dividend tax rate depends not only on the dividend amount but also on the net asset position of the firm. For an individual firm owner, the entire region is not available, and the firm’s net assets define a restriction that slices the three-dimensional dividend tax schedule. For example, a sole owner of a firm with exactly 1 million euros of net assets could locate exactly at the corner of the lowest plane. By receiving more dividends, the owner would face the earned income schedule, which is the high uneven plane in the graph. The earned income tax rates above the threshold are calculated as averages of the individual marginal tax rates of owners at the threshold.
1.2 Bunching method
I estimate the extent of excess mass and the according elasticity of taxable income using the bunching method developed by Saez (2010)Footnote 33. The elasticity of taxable income (ETI) is the ratio of a percentage change in taxable income to a percentage change in the net-of-tax income rate (one minus the tax rate). The bunching method uses the excess mass at a tax schedule discontinuity to estimate the corresponding elasticity of taxable income.
To measure excess mass, I first estimate a counterfactual distribution that describes what the dividend distribution would approximately be in the absence of the kink pointFootnote 34. The counterfactual distributions around the monetary kink points are estimated as
where \(\widehat{C_{j}^{0}}\) is the estimate of the counterfactual distribution in each bin j with dividend income \(Z_{j}\). \(\beta _{i}^{0}\) are the regression estimates, and p denotes the degree of the polynomial. \(\rho\) in the second term captures the round number fixed effect that is observed in Fig. 1. \(\left[ -R;R\right]\) is the excluded range of the distribution, which denotes the area where the kink point affects the owners’ behavior. Following earlier literature (e.g. Chetty et al., 2011), this area is selected by visual observation of the data. My results and conclusions are not sensitive to the choice of \(\left[ -R;R\right]\) or the order of the polynomial.
I estimate the counterfactual distribution around the net asset threshold following Eq. (3).
The basic principle is the same as in Eq. (2). Given the very strong bunching, the second term is used to spread the bunchers to the surrounding region to make the sum of firms in the counterfactual distribution match that of the realized distribution. For this distribution, there is no need to consider round number bunching. In estimating the counterfactual distribution, I include both the region below and above the threshold, as the system is likely to induce early payments of dividends, as discussed in Kari and Laitila (2015).
The sum of the excess observations in the bunching range is
The estimate of excess bunching \(\hat{b}\) is then the estimated excess mass around the kink relative to the average density of the counterfactual dividend distribution between \(-R\) and R
Finally, the excess bunching can be turned into an elasticity estimate. The elasticities at the kink points are estimated as
D denotes dividend income, \(\tau\) the dividend income tax rate that jumps at a kink point \(D^{*}\) from \(\tau _{D}\) to \(\tau _{D}+\triangle \tau _{D}\). When estimating the elasticities at the net asset thresholds, I specify the marginal tax rate above the threshold for each firm owner individually. Then I use the aggregate bunching response to estimate the elasticity for each owner and report the mean elasticity.
Following earlier literature, I use the bootstrap method to construct standard errors (see Kleven (2016) for a review). In the bootstrap method, I sample the residuals from the regression a large number of times (300), with replacement, and estimate an elasticity for each draw. Using these elasticities, I calculate a standard error for the original elasticity estimate.
1.3 Additional empirical details
Table 15 gives the summary statistics for the full data. Altogether, the data consist of 641,558 observations across 11 years.
Figure 13 shows how various industries are represented in each bin around the 90,000 EUR threshold. The horizontal dashed line shows the industry’s average share in the data. The figure shows that the finance industry is overrepresented among the firms bunching at the monetary threshold.
Table 16 shows the proportion of firms that move together with the threshold. When the monetary threshold moved from 90,000 EUR to 60,000 EUR, 47% of the preceding excess mass firms followed the threshold. At the 150,000 EUR threshold, one third of the observations had previously paid exactly 60,000 EUR of dividends, which was the preceding threshold. At the 8% net asset threshold, 70% of firms had previously bunched at the 9% threshold.
Figure 15 shows the income composition in two consecutive years when there was no tax change. There is now no change in the owners’ income composition. The figure acts as a robustness check that the shift observed in Fig. 4 was driven by the tax change.
Figure 14 shows the accumulation of aggregated assets in privately held corporations in 2000–2016. Net assets consists of retained earnings, financial assets, and additions to depreciating capital. The figure also shows the evolution of aggregated profits, dividends and net investment in depreciating capital. The figure shows a clear increase in accumulated assets, starting especially after the introduction of the current dividend tax system in 2005. There is no increase in aggregate investment, so this is not likely to solely explain the accumulation of assets.
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Koivisto, A. Tax planning and investment responses to dividend taxation. Int Tax Public Finance (2024). https://doi.org/10.1007/s10797-024-09837-w
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DOI: https://doi.org/10.1007/s10797-024-09837-w