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Ongoing project

Redesigning the Dividend Withholding Tax & Closing the Loopholes (TAXLOOP)

Investors across Europe have for years exploited loopholes in dividend withholding tax rules to avoid taxation or claim unwarranted refunds. TAXLOOP maps the scale of these schemes and assesses which regulatory responses are effective.

Project period 2025–2026
Project nr. 10909 // NFR: 300955

In 2018, the European journalist network CORRECTIV exposed the largest tax fraud in European history. Through so-called cum-schemes — cum-cum, cum-ex, and cum-fake — investors have systematically exploited weaknesses in national dividend withholding tax (DWT) rules, with estimated revenue losses across Europe exceeding €200 billion.

TAXLOOP analyses trading patterns and regulatory frameworks across at least 17 European countries to identify which countries have been affected, quantify revenue losses, and assess what makes regulation effective. A key finding is that Denmark's 2016 reform — which required shareholders to confirm beneficial ownership — raised annual DWT revenues by approximately 130 percent. Norway's 2019 reform, which lacked this requirement, had no measurable effect. The project also examines the interaction between dividend taxation and wealth taxation, showing that a wealth tax can, under certain conditions, offset firms' incentives to defer dividend payments.

The project applies econometric methods, machine learning, and optimal tax theory, and is the first to provide a comprehensive European-level analysis of cum-scheme activity and effective policy responses.

Participants

Julie Brun Bjørkheim Senior Research Fellow +47 922 54 759 Send e-mail

Publications

  • Bjørkheim, Julie Brun; Iden, Hanna; Kristoffersen, Marte & Zoutman, Floris Tobias (2026). The Missing Paper Trail: Comparing Dividend Withholding Tax Enforcement in Norway to Denmark. Norges Handelshøyskole. Institutt for foretaksøkonomi. Full text in Research Archive

View all works in NVA

Research topics: economics
Published June 29, 2026 2:15 PM - Last modified June 29, 2026 2:16 PM