Felix Somary: Taxing Companies or Shareholders

Felix Somary’s brief stenographic intervention, originally published within proceedings in 1918, asks where a levy on wealth should be imposed: on companies or on their shareholders. Its structure moves from a principle of public finance to a practical choice of tax subject, then to the reasons for Somary’s preferred solution.

Es entspricht zweifellos den Grundsätzen der Finanzwissenschaft, daß eine Doppelbesteuerung unter allen Umständen vermieden werden muß.

English translation: It undoubtedly accords with the principles of public finance that double taxation must be avoided under all circumstances.

Avoiding double taxation supplies the governing constraint, not a complete answer. Somary distinguishes the company from its owners as alternative points of assessment:

Ich möchte nur die Frage zur Diskussion stellen, ob die einzelnen Gesellschaften oder die Aktionäre zur Vermögensabgabe heranzuziehen sind.

English translation: I merely wish to put up for discussion the question of whether the individual companies or the shareholders should be subject to the wealth levy.

Although he presents this as an invitation to discussion, Somary recalls having already recommended taxing companies in an earlier expert opinion. His justification combines administrative feasibility with tax equity: companies permit easier and more complete assessment, whereas taxing individual shareholders would necessarily depend on stock-market prices at one or more reference dates. The conceptual move is to make valuation procedure part of the question of fairness, rather than treating collection as a merely technical matter.

The intervention thus identifies a tension between corporate wealth and its market valuation in shareholders’ hands. Somary closes by acknowledging reservations about corporate taxation. The wording of that final qualification is textually unclear and requires review before its precise technical meaning can be established.