The allowance for shareholder equity tax system introduces a tax-deductible
allowance for the normal return on equity at the shareholder level. The part of the dividend
or the capital gain that corresponds to the “normal” rate of return is tax-free in the hands
of the shareholder and the rents are subject to a shareholder-level tax. The corporate tax
rate continues to function as the backstop to the personal income tax also under the ASE
tax system.
The ASE tax system is therefore an interesting position between a full
imputation system and a classical tax system. Under this corporate income tax system,
there is no debt-equity distortion in a closed-economy. In fact, the ASE tax system does not
require expenditure tax treatment of savings at the personal level in order to obtain full
neutrality with respect to the marginal sources of finance in a closed-economy.
Moreover,
the cost of capital of (marginal) equity-financed investment might decrease, which will
stimulate investment by the residents of the country that implements the ASE tax system.
However, in order to obtain the neutrality features of the ASE tax system, the corporate.