1. What is the current legal landscape for Tax in your jurisdiction?

Norway has a well-established and relatively stable tax system, although the tax landscape is continuously shaped by legislative developments, international initiatives and an increasing focus on transparency, reporting and anti-avoidance measures. The primary source of Norwegian tax law is the Tax Act of 1999, supplemented by the Tax Administration Act of 2016 and a broad range of regulations and administrative guidance. Norway also has an extensive tax treaty network, with approximately 90 bilateral tax treaties, largely based on the OECD Model Tax Convention.

Norway applies a residence-based system of taxation. Norwegian tax residents are generally liable to tax on their worldwide income and wealth, while non-residents are primarily taxed on Norwegian-source income and assets. Individuals may become tax resident based on physical presence in Norway, generally after exceeding 183 days in a 12-month period or 270 days in a 36-month period. Importantly, Norwegian tax residence does not necessarily cease immediately upon departure, and specific conditions apply to individuals who emigrate.

Resident companies are generally subject to Norwegian corporate income tax at a rate of 22 per cent on their worldwide net income. Norway also has a participation exemption regime under which qualifying dividends and capital gains received by corporate shareholders are broadly exempt from taxation, although a limited portion of dividends may remain taxable. Individual shareholders are taxed more heavily on dividends and capital gains, with an effective rate significantly above the general 22 per cent rate due to Norway’s shareholder taxation system.

The tax treatment of foreign companies depends on their connection to Norway. A company is resident in Norway, and thus subject to worldwide taxation, if it is incorporated under Norwegian law or has its place of effective management and business in Norway, unless a tax treaty allocates residence elsewhere. Foreign companies that do not meet this threshold are still subject to limited tax liability on Norwegian-source income, including income from a Norwegian branch or business activities carried out in, or managed from, Norway. Determining whether this threshold is crossed, and how it interacts with Norway’s tax treaty network, is often decisive for foreign investors entering the market.

Norway also imposes a net wealth tax on individuals, which continues to distinguish the Norwegian tax system from many other European jurisdictions. Capital assets, including shares, are generally included in the wealth tax base, although valuation discounts may apply to certain assets.

Exit taxation has become an increasingly important feature of the Norwegian tax landscape. Individuals who cease Norwegian tax residence may become subject to tax on unrealised gains on shares and certain other financial assets, and the rules have been significantly tightened in recent years.

VAT is another key component of the system. Although Norway is not a member of the European Union, and its VAT system is therefore not governed by the EU VAT Directive, Norway operates a broadly similar consumption tax model. The standard VAT rate is 25 %, with reduced rates applying to certain goods and services, including a 12 % rate for some activities. Other transactions may be subject to a zero rate or are exempted from VAT, depending on the nature of the supply.

Norway has also implemented extensive rules on transfer pricing, controlled foreign companies, interest deductions, Pillar 2 global minimum tax framework and anti-avoidance. An increased focus on digital reporting, beneficial ownership transparency and international tax cooperation means that compliance and documentation remain central considerations for both Norwegian and multinational businesses.

2. What three essential pieces of advice would you give to clients involved in Tax matters?

a. Stay ahead of a politically dynamic tax landscape

Norway remains a highly attractive jurisdiction for investment and residency: a stable democracy, strong rule of law, and a fundamentally sound economy. What has changed is the speed and frequency of legislative change to the tax rules themselves. Recent wealth tax increases prompted several high-net-worth individuals to relocate abroad, most notably to Switzerland, sparking a sustained political debate on the future shape of the tax system. That process is now producing results: the government’s Tax Commission has proposed tax cuts of up to NOK 23 billion, signalling real political will to improve conditions for owners and investors, even as the details continue to be debated. With that said, Norway remains a country of real possibility, and for foreign investors and individuals alike it can be an ideal place to invest and build a long-term presence. The day count, however, is crucial: precise tracking of days spent in Norway, and of the timing of any move, is often what determines whether a client captures that opportunity on favourable terms.

b. Think long-term when relocating to or investing in Norway

Norway offers strong fundamentals, a skilled workforce, and sectors actively seeking capital and ownership continuity. Clients should look beyond the immediate tax consequences of a single transaction. A current structural advantage for foreign ownership relative to Norwegian ownership creates a real window for foreign capital to enter the Norwegian market, including through acquisitions of established Norwegian companies. Clients who plan with a long horizon, rather than optimising for year one, are best placed to capture this advantage and build a Norwegian presence that performs well as reforms are finalised.

c. Plan early, document your position, and involve advisers before you relocate

With Norway’s tax rules moving toward a new equilibrium, timing and preparation matter. Residency changes and cross-border investment structures should be mapped out well in advance, with contemporaneous documentation of intentions, dates, and valuations to support a smooth process and withstand scrutiny if required. Clients should engage advisers before taking significant steps, so structures are built to perform under current rules and adapt smoothly as reform is finalised.

3. What are the greatest threats and opportunities in Tax law in the next 12 months?

The political landscape in Norway has given rise to several significant tax law changes in recent years. Increased overall taxation, particularly through higher wealth taxation and stricter exit tax rules, has contributed to a noticeable outflow of high-net-worth individuals from Norway and sparked a wider debate on the future direction of the tax system. This debate ultimately led to the appointment of a new tax commission, the second in four years following the Torvik Committee in 2022. In June 2026, the commission published its report, which received broad cross-party support for most recommendations, although with the notable exception from the Progress Party (FrP), currently Norway’s largest party. Whether, and in what form, the recommendations will be implemented remains subject to political compromise and parliamentary negotiation. Taxpayers should therefore follow developments closely and consider seeking legal and tax advice at an early stage to ensure compliance and to allow for effective planning under both the current rules and any future framework, including possible transitional provisions.

a. Changes in the wealth tax

Among the commission’s recommendations is the elimination of the existing valuation discounts applied to certain assets, such as shares, holiday homes, primary residences, aquaculture licences and business assets.

Instead of valuation discounts for wealth tax purposes, the commission proposes: (i) reducing the effective tax rate to within a range of 0.25 % to 0.75 %, down from the current rates of 1 % and 1.1 %; (ii) increasing the general basic allowance; and (iii) introducing a separate basic allowance for primary residences.

The overall revenue effect of the wealth tax proposals is estimated at a net reduction of between NOK 6.3 billion and NOK 25.2 billion, depending on the effective rate chosen and the relative increase in the general basic allowance. The proposed changes are expected to offer material tax relief, in particular for high-net-worth individuals.

Given the scale of the proposed amendments, transitional rules are likely to be introduced, and taxpayers should expect a period of legislative uncertainty before the final framework is settled. In this environment, careful planning and advice will be important to assess the timing of any disposals, restructurings or relocation decisions, and to ensure that taxpayers can navigate the transition without unintended tax consequences.

b. Changes in tax breaks for the sale of primary residences and holiday homes

Under the current legislation, primary residences can be sold tax free provided the taxpayer has owned the property for more than one year at the time of divestment and has used the entire property as his or her primary residence for no less than one of the last two years before divestment. Similarly, holiday homes may be exempt from tax on gains if the owner has used the property as his or her holiday home for no less than five out of the last eight years prior to the divestment.

The commission has recommended tightening the conditions for tax-exempt gains on the sale of primary residences by increasing both the ownership period and the period of actual use as a primary residence from one year to three years. The proposal may also be combined with a proportional taxation model, under which gains could be taxed to the extent the owner has not used the property as a primary residence during the relevant period. In addition, the commission recommends abolishing the current tax exemption for gains on the sale of holiday homes. For holiday homes that already satisfy the current exemption requirements, the commission proposes a transitional rule under which the tax basis would be stepped up to market value, thereby limiting future taxable gains to value increases occurring after the new rules take effect.

Although the final rules remain subject to political clarification, stricter taxation of private real estate gains is expected. Individuals with several properties, including holiday homes, should therefore assess their position at an early stage and involve legal and tax advisers to evaluate timing, documentation and possible transitional effects before making any disposals or restructuring decisions.

c. Changes in the exit tax

Under the current exit tax legislation, 70 % of dividend distributions during the deferral period must be applied to repay the exit tax liability, which falls due in full after 12 years regardless of any subsequent fall in share value. The commission proposes reducing this proportion to the standard dividend tax rate on share income, currently 37.84 %.

The commission also proposes to soften the existing exit tax rules by allowing taxpayers to claim a deduction for post-emigration losses, provided the relevant assets are disposed of within three years after emigration.

For inbound residents, the commission also proposes an exemption from exit tax for individuals who are only temporarily resident in Norway. Under the Danish approach, individuals are not subject to exit tax where their residence in Denmark has not exceeded seven years in total during the preceding ten-year period. Germany applies a comparable exemption for individuals who have been resident there for no more than seven of the preceding twelve years.

The proposal appears inspired by the Danish and German models and is intended to strengthen Norway’s attractiveness for highly skilled international workers, investors and entrepreneurs. The commission is explicit that the risk of a future exit tax charge can itself influence whether skilled individuals choose to move to Norway at all, an effect it views as particularly relevant for the knowledge-based businesses, research institutions and start-ups that most need to attract such talent. Framed this way, the proposal is less a technical relief measure than a recognition that Norway’s tax settings are, in this respect, a competitive lever it can choose to use.

The proposals are expected to be reflected, at least in part, in the 2028 National Budget, which is scheduled for publication in October 2027.

d. Changes in paid-in capital

Under current rules, the tax position “paid-in capital” attaches to the share rather than the shareholder, which has created administrative complexity and scope for tax planning. Two alternative changes have been proposed by the Ministry of Finance: either retaining tax free repayment of previously paid-in capital, but capped at the shareholder’s own tax cost base, or allowing tax free distributions up to the shareholder’s tax cost base regardless of the amount historically paid in on the share. In both cases, existing opportunities to utilise paid-in capital positions may be reduced or lost. Currently, the second option appears the more likely, though confirmation will only be obtained upon the presentation of the 2027 National Budget in October 2026.

As the changes are proposed to take effect from 1 January 2027, shareholders should act now to: (i) map their individual tax cost bases and the relevant company’s paid-in capital position; (ii) verify the supporting documentation where necessary; and (iii) assess whether it may be beneficial to make tax free distributions during 2026. This is particularly important where corporate law procedures, creditor notice periods or adviser input are required before funds can be distributed.

e. Proposed withholding tax on liquidation distributions

Under current Norwegian tax rules, the liquidation of a limited liability company is generally treated as a realisation of the shares, meaning that liquidation distributions are taxed as capital gains rather than dividends. For foreign shareholders, this may create opportunities for tax planning, as a liquidation may in many cases avoid Norwegian withholding tax that would otherwise apply to dividend distributions. In many tax treaties, the taxing right over capital gains is allocated exclusively to the shareholder’s state of residence. To address this, the commission recommends that liquidation distributions representing retained earnings should instead be classified as dividends and made subject to Norwegian withholding tax.

Investors should therefore monitor the legislative process closely, as the timing of investments in, and potential exits from, Norwegian projects may become increasingly important.

4. How do you ensure high client satisfaction levels are maintained by your practice?

Aider Legal maintains high client satisfaction by combining strong technical expertise in tax law with a highly responsive and practical approach to client service. Our advisers closely follow legal, political and commercial developments that may affect our clients, enabling us to provide timely and forward-looking advice. We also focus on delivering clear, commercially viable solutions rather than purely theoretical assessments.

As part of the Aider-group, a multidisciplinary professional services firm, we work closely with specialists across other financial and advisory disciplines, allowing us to draw on broader expertise where needed. Our team also brings experience from both the private sector and public authorities, providing valuable insight into how the authorities may approach and assess particular issues. Combined with short response times and a strong focus on understanding our clients’ businesses, this enables us to provide advice that is both technically robust and practical.

 5. What technological advancements are reshaping Tax law and how can clients benefit from them?

Norway has a highly digitalised tax administration. Tax returns, reporting and communication with the tax authorities are now predominantly digital, while standardised reporting requirements such as SAF-T give the authorities increasingly structured access to taxpayers’ financial data.

At the same time, tax administration is becoming increasingly interconnected across borders. Norwegian authorities participate extensively in international information exchange, allowing financial, ownership and other tax-relevant information to be shared and compared across jurisdictions. Much of this takes place automatically and largely unnoticed by taxpayers. For international businesses and individuals, this makes consistency between reporting in different jurisdictions increasingly important.

The same technological development also creates significant opportunities for taxpayers. Automated accounting and reporting systems can reduce manual processes, improve data quality and make both domestic and cross-border compliance more efficient.

Artificial intelligence is the next important development. AI already has considerable potential in tax research, document review and the analysis of large volumes of financial and legal information. Used correctly, it can make both internal tax functions and external advisers more efficient. However, tax advice frequently depends on nuanced legal interpretation and a detailed understanding of the underlying facts. AI should therefore complement, rather than replace, professional judgement, particularly where the underlying facts are complex or the tax consequences are significant.

For clients, the key opportunity is to view digitalisation as more than a compliance exercise. Businesses that combine reliable systems and high-quality data with appropriate tax expertise can reduce compliance costs, identify risks earlier and make better-informed commercial decisions. As tax authorities gain access to increasingly sophisticated technology and cross-border information, strong tax governance is also becoming more important than ever.

6. Describe a particularly interesting or complex matter you have advised on recently, and explain the challenges involved, your approach, and the outcome achieved for the client?

Permanent establishment (“PE”) exposure is one of the most recurring issues we advise on for foreign groups carrying out multi-phase projects in Norway, and the fact pattern below is one we see repeatedly across industries: a foreign group planning a multi-year Norwegian project involving both equipment installation and long-term servicing sought advice on structuring the engagement as two genuine, independently defined scopes of work, reflecting the commercially separate nature of the installation and maintenance phases, without exposing the group to an unintended permanent establishment.

The Norwegian tax authorities do not accept contractual labels at face value; they look through the contractual structure to whether the work in substance forms a single commercially and geographically coherent project (as illustrated by a 2023 Tax Appeals Board decision involving a foreign contractor’s installation work at a Norwegian shipyard, where several formally separate short assignments were aggregated into a single project because they formed one continuous commercial undertaking). The risk for our client was that a poorly structured split between the installation and the subsequent maintenance contract could be similarly re-characterised, triggering PE status and full Norwegian taxation on both phases.

We advised on structuring the installation and maintenance scopes as genuinely independent engagements from the outset, with separate contractual counterparties or clearly distinct scopes, independent commercial terms, a defined contractual milestone (a Taking-Over Certificate) marking the transition from installation to maintenance, and documentation establishing that the maintenance arrangement was not pre-committed at the time the installation contract was signed. We also advised on tracking the cumulative on-site presence under each phase separately to keep the installation period within the applicable tax treaty’s construction/installation threshold.

The client was able to proceed with the project on the intended contractual structure, with the installation phase completed within the treaty threshold and the maintenance phase assessed independently, avoiding an unintended permanent establishment and the associated Norwegian corporate tax exposure, while remaining fully documented and defensible if challenged by the tax authorities.

This distinction between a genuine, independently scoped engagement and a single continuous project is one we return to in more depth in our accompanying hot topic article, “Winning Work in Norway: A Practical Roadmap for Foreign Contractors and Investors,” which sets out the broader framework foreign contractors and investors should apply when structuring Norwegian project work from the bid stage onward.

About Aider Legal

Helping Companies Succeed When Doing Business in Norway

Aider Legal is a distinguished full-service Norwegian business law firm dedicated to helping foreign companies establish and succeed in the Norwegian market.

We provide comprehensive legal support to clients across industries — from startups to multinational corporations, as well as Norwegian businesses expanding their operations. Our multidisciplinary team of lawyers and legal advisors assists in all key areas of business law, including tax law, VAT and customs, corporate law, labor law, and global mobility.

Through our close collaboration with Aider, our clients also gain seamless access to accounting, payroll, reporting, and broader advisory services when needed.

With offices in Oslo, Bergen, Stavanger, and Trondheim, we are committed to delivering quality, perseverance, and tailored legal solutions — your trusted legal partner and one-stop-shop for doing business in Norway.

Aider Legal was established through the merger of Magnus Legal, Aider Lawyers, and Strandenæs Law Firm, and is part of the Aider Group.

Aider Legal is a member of the Norwegian Bar Association. In addition, for smooth cross-border operations, we are members of the MSI Global Alliance and ETL Global, allowing us to connect you with the right lawyers and professional advisors regardless of where you do business.

About Aider Group

Aider Group is a professional services group combining accounting, advisory, and legal expertise to help businesses grow, structure, and succeed in Norway.

Two teams. One coordinated client experience. Together, we are your one-stop-shop partner for doing business in Norway.