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The tax hole for the richest saved Salmar’s heir more than 200 million tax crowns in two years. Now the hole is closed.
According to the 2017 and 2018 tax lists, the billionaire Salmar Gustav Magnar Witzøe (27) was listed with a fortune of around NOK 1 billion, ten billion less than in 2016. In 2019, fortune returned to go up and exceeded NOK 20 billion.
In 2006, the founder of Salmar Gustav Witzøe (67) transferred almost all the shares of the salmon empire to his son Gustav Magnar, and by age 23 his son had more than 11 billion in assets.
But in 2017, the fortune was suddenly reduced to just over a billion crowns. Therefore, the heir also escaped with much less estate tax. Similar figures were presented the following year.
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Jumped again
However, when the 2019 tax figures became available, Witzøe again increased his wealth by almost 2000 percent, from NOK 1.02 billion in 2018 to NOK 20.68 billion in 2019, according to the tax figures that Nettavisen has had access to.
This is a clear new record in the fortune of Witzøe, who was Norway’s richest in 2016 with a fortune of NOK 11 billion.
Despite Nettavisen not having access to all of last year’s tax figures, a fortune of almost NOK 21 billion is more than enough to put the 27-year-old on top of the magnificent earnings in Norway.
TOP AND BOTTOM: Gustav M. Witzøe had two years with considerably reduced wealth and therefore lower taxes. A new law has eliminated this possibility for tax planning.
Photo: Håkon Mosvold Larsen (NTB scanpix)
Rearranged and received a discount.
According to DN, a reorganization of the company structure was the reason why the tax was reduced by NOK 84 million in 2017. Also in 2018, Witzøe also received a large discount on the valuation of Salmar shares, despite that the fish company is publicly traded and is therefore normally valued at the market price of the shares. .
Ownership of the listed salmon farming company Salmar was reorganized and, due to the restructuring, Witzøe did not have to tax the actual market value of the shares for two years. Instead, the tax was calculated on the sum of the capital stock divided by the number of shares and share premiums of the owner companies.
Over the course of two years, Witzøe saved around NOK 220 million in taxes, DN’s calculations show, which are based on the price of shares at the end of the year during the two years it benefited from the calculation of adjusted wealth.
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The fiscal hole is closed
Now this fiscal hole is closed, and this is the explanation for the increase in Witzøe’s net wealth last year by almost 2,000 percent to NOK 20.1 billion. Then the wealth tax was also increased from 168 to 223 million crowns.
Before Christmas 2019, the Storting passed an amendment to the tax law that removes the tax hole that Witzøe had used. In the amendment, this is formulated as “unlisted shares in start-ups will no longer be valued based on share capital and share price, but will follow the same rules as other unlisted shares.”
With this change, it will no longer be possible to reduce the value of assets by reorganizing the structure of the company.
Also read: Witzøe and Salmar with huge profits: won 270 million in a reinforced crown
– More difficult to plan taxes.
– You could make a capital increase of the wealth base so that the limited company is valued differently. This could be done from time to time, but now it is no longer possible, Ole Gjems-Onstad, professor and tax law expert, tells Nettavisen.
– What consequences does this have?
– The company can no longer be reorganized to obtain a different valuation. That means a smaller customization option, so you can tell it bites a bit more. But it must be said that those who have been able to do this must have large stakes, since the expenses of tax advisers and auditors increase rapidly. You had to get big savings to make it worth it.
THE HOLE WAS CLOSED: – The company can no longer be reorganized to obtain a different valuation. This means less adaptability, so it’s arguably a bit more difficult, says BI professor Ole Gjems-Onstad.
Photo: Christian Bakken (Nettavisen)
With a million crowns on equity basis, the above opportunity would yield 5,500 in saved taxes, says the professor, who estimates that the costs for implementing the tax refund would be around 100,000 crowns.
Given the costs, it is mainly those with large fortunes who had the opportunity to save something special. Tax planning is still not impossible, but if the assets are in Norwegian hands, the possibilities are quite limited now, the professor believes:
– Basically now it is not so easy to adjust the wealth tax, says Gjems-Onstad.
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