Is the Norwegian government’s theory that a modern company might never realize their gains, and avoid taxation indefinitely, and thus this is a forcing mechanism to extract some tax revenue?
I don't know how a company could avoid all taxes. They say that Amazon does, but that's only the corporate income tax, surely they are paying billions in payroll, property, energy, and other taxes.
The wealth tax targets millionaires who structure their income so they don't pay income or corporate tax, but can't avoid owning assets like company shares and property. Loss-making startups with unicorn level valuations are a tiny edge case.