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Comparative Analysis of Dividend and Capital Gains Taxation: Implications for Investment Decisions in OECD Countries; [Сравнительный анализ налогообложения дивидендов и прироста капитала: последствия для инвестиционных решений в странах ОЭСР]

Journal of Tax Reform | 2026

Paper Details

Authors: Chikhaoui M.

DOI: 10.15826/jtr.2026.12.1.240

Journal: Journal of Tax Reform

Year: 2026

Publisher: Ural Federal University

Document Type: Article

Open Access: All Open Access; Gold Open Access; Green Open Access

Cited by: 0

Abstract

This paper examines tax arbitrage between dividend income and capital gains in an international comparative framework. While traditional financial theory states that the tax treatment of dividends and capital gains should be neutral when markets op-erate without constraints, tax systems applied to individuals and businesses alter this balance and creating investor preferences. This study examines how 16 OECD mem-ber countries taxed dividends and capital gains from 2013 to 2023, focusing on actual fiscal treatment, double taxation relief, exemption rules, and capital gains deduction policies for different holding periods. The analysis uses a basic net after-tax income maximization and a logit probability model applied to a benchmark investment. The results reveal a general preference for capital gains in most studied countries, espe-cially when long-term gains are favored under favorable tax regimes. The double taxation of dividends makes them less attractive, while the stability and structure of tax regimes become key factors in investment decision-making. The estimated probabilities confirm a strong preference for capital gains in nearly all OECD countries. In countries such as Germany, France, Italy, and Belgium, the high probabilities of choosing capital gains are explained by net ratios greater than one, indicating that the expected net income from capital gains exceeds that from dividends. Conversely, in countries such as Ireland and Portugal, the logit model shows more balanced pro-babilities, reflecting more favorable dividend taxation or specific exemption schemes for capital gains. The findings highlight the importance of combined effective rates and specific tax provisions in capital allocation and contribute to the literature by providing an integrated international comparison of tax incentives affecting capital income choices in an environment of increased capital mobility. © Chikhaoui M., 2026.

Keywords

capital gains; dividends; effective tax rates; OECD countries; probability of investor choice; tax arbitrage