{"id":113676,"date":"2025-10-09T11:04:32","date_gmt":"2025-10-09T11:04:32","guid":{"rendered":"https:\/\/my.legal500.com\/guides\/?post_type=comparative_guide&#038;p=113676"},"modified":"2025-10-09T11:04:32","modified_gmt":"2025-10-09T11:04:32","slug":"norway-tax","status":"publish","type":"comparative_guide","link":"https:\/\/my.legal500.com\/guides\/chapter\/norway-tax\/","title":{"rendered":"Norway: Tax"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-113676","comparative_guide","type-comparative_guide","status-publish","hentry","guides-tax","jurisdictions-norway"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Thommessen (Advokatfirmaet Thommessen AS)<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/12\/thommessen.jpg\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Thommessen (Advokatfirmaet Thommessen AS)<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/my.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/12\/thommessen.jpg\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Tax laws and regulations applicable in Norway<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How often is tax law amended and what is the process?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Tax legislation in Norway is typically amended as part of the annual budget process, which is presented by the Government in October, before the end of the financial year, and again in May in the following financial year in connection with the presentation of the revised budget. However, tax reforms and other major tax amendments may also be presented before the Parliament in a separate bill.<\/p>\n<p>Normally, a tax bill shall be circulated for public consultation, with a consultation period of up to three months. Feedback received from consultation bodies may lead to revisions or adjustments to the draft tax bill before it is submitted to Parliament. The usual processing time of a tax bill in Parliament is three to six months.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the principal administrative obligations of a taxpayer, i.e. regarding the filing of tax returns and the maintenance of records?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A taxpayer (whether a company, person or other entity) is required to file an annual tax return with the Tax Authorities and to address any tax-related questions, providing all information relevant to the tax assessment. The tax return for each income year is normally submitted the 30 April for private individuals and 31 of May for companies, in the following year. Failure to submit a mandatory tax filing, or to provide insufficient information to the Tax Authorities, may result in penalties or criminal charges.<\/p>\n<p>Businesses subject to bookkeeping regulations are required to retain records for five years. However, the Norwegian Tax Directorate (<em>Nw: Skattedirektoratet<\/em>) may require a longer retention period in connection with tax audits.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Who are the key tax authorities? How do they engage with taxpayers and how are tax issues resolved?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The Ministry of Finance is responsible for developing tax policy, presenting tax legislation to the Parliament, and negotiating Norway&#8217;s double tax treaties. The Tax Directorate acts as the executive agency under the Ministry, providing guidance and instructions to the regional and local tax offices. These tax offices are the primary point of contact for taxpayers, handling tax administration, collection, and day-to-day inquiries. Tax decisions made by the tax offices can be appealed to an independent Tax Appeal Board. If a taxpayer is dissatisfied with the outcome, decisions from either the tax office or the Appeal Board can be further challenged before the Norwegian courts.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are tax disputes heard by a court, tribunal or body independent of the tax authority? How long do such proceedings generally take?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, tax disputes in Norway can be heard by bodies independent of the tax authority. Initially, if a taxpayer disagrees with a decision made by the tax office, they may appeal to the independent Tax Appeal Board (<em>Nw: Skatteklagenemnda<\/em>), which is separate from the tax administration. If the taxpayer is still dissatisfied with the outcome, the case can be brought before the ordinary Norwegian courts, which are fully independent of the tax authorities. Alternatively, the taxpayer can bring the decision from the tax office directly before the ordinary Norwegian courts, without first appealing to the Tax Appeal Board.<\/p>\n<p>The duration of such proceedings varies. Appeals to the Tax Appeal Board typically take a year to several years, depending on the complexity of the case and the Board\u2019s caseload. If the dispute is brought before the courts, it may first be heard by the City Court, then the Court of Appeal and, as a final instance, the Supreme Court. Consequently, a tax case may be subject to court proceedings that extend over several years.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the typical deadlines for the payment of taxes? Do special rules apply to disputed amounts of tax?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>For most individuals, any balance of tax due (after assessment) is typically payable in two equal installments. The first installment is usually due about three weeks after the tax assessment notice is issued (generally in June or August), and the second installment is due about eight weeks after the notice. If you are self-employed, advance tax payments are made in four installments throughout the year (March, May, September, and November).<\/p>\n<p>Companies generally pay tax in advance in two installments, which falls due on 15 February and 15 April in the year following the income year. Any additional tax due after the final assessment must be paid within three weeks of receiving the assessment notice. Value Added Tax (VAT) payments are generally due every two months.<\/p>\n<p>Employers are obligated to withhold and pay taxes on employment income throughout the financial year (six installments), in addition to payment of the employers\u2019 national insurance contributions.<\/p>\n<p>If a taxpayer disputes a tax assessment and files an appeal, the general rule is that the assessed tax must still be paid by the original deadline, even if the amount is under dispute. However, the taxpayer can apply to the tax authorities for a deferral (postponement) of payment for the disputed amount. The authorities may grant a deferral if there are reasonable grounds, but interest may accrue on the deferred amount. If the appeal is successful and the tax is reduced, any overpaid amount will be refunded with interest.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are tax authorities subject to a duty of confidentiality in respect of taxpayer data?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, the Tax Authorities are subject to a strict duty of confidentiality with respect to data and information received from taxpayers and third parties. The tax authorities may only disclose personal or sensitive information if there is a clear legal basis for doing so, such as specific provisions in law or a court order.<\/p>\n<p>To ensure compliance with confidentiality and information security requirements, the tax authorities have established their own management system to safeguard taxpayer data and ensure that all applicable legal and regulatory standards for information security and privacy are consistently met.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is this jurisdiction a signatory (or does it propose to become a signatory) to the Common Reporting Standard?  Does it maintain (or intend to maintain) a public register of beneficial ownership?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway is a signatory to the Common Reporting Standard (CRS). Norway has implemented the CRS, which provides for the automatic exchange of information between participating jurisdictions to combat tax evasion, international tax crime and improve transparency. Under these agreements, the Norwegian Tax Administration receives information concerning Norwegian taxpayers&#8217; financial capital and assets held in foreign financial institutions from foreign tax authorities.<\/p>\n<p>The Register of Beneficial Owners was introduced with effect from 1 October 2024, with mandatory registration by 31 July 2025. This public register provides an overview of individuals who effectively control businesses and was established to counter money laundering, terrorist financing and economic crime. However, as of 2025, the register is not fully public. Access is currently limited to certain authorities and entities with a legitimate interest, in line with recent European Court of Justice rulings on privacy. Norway has previously expressed an intention to make the register fully public, but full public access is pending further legal and regulatory developments.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the tests for determining residence of business entities (including transparent entities)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Pursuant to Norwegian domestic tax law, companies are considered resident in Norway for tax purposes if they are incorporated pursuant to Norwegian company law or if their effective management is exercised in Norway. Additionally, any business activity conducted in or administered from Norway is subject to Norwegian corporate tax on a limited tax liability basis.<\/p>\n<p>Transparent entities, such as partnerships, are not subject to income tax at the entity level, as their income is allocated and taxed directly in the hands of the partners.<\/p>\n<p>The determination of tax residency and limited tax liability is made irrespectively of organizational formalities. However, tax residency may be affected by applicable tax treaties, which is generally based on the OECD Model Tax Convention. Under such treaties, a company will not be considered resident in Norway if it is resident in another state according to the relevant tax treaty&#8217;s tie-breaker rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do tax authorities in this jurisdiction target cross border transactions within an international group? If so, how?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, the Tax Authorities actively scrutinize cross-border transactions within international groups. Such transactions are assessed and taxed in accordance with the OECD transfer pricing standard, requiring all intra-group dealings be conducted on arm\u2019s length terms. Norwegian tax legislation imposes specific documentation and reporting requirements on companies to demonstrate compliance with the arm&#8217;s length principle. The Tax Authorities may conduct audits and request detailed transfer pricing documentation to verify that transactions are properly priced. If non-compliance is identified, the authorities have the power to adjust a company&#8217;s taxable income to reflect arm&#8217;s length values and may impose penalties or interest on any resulting tax shortfall.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a controlled foreign corporation (CFC) regime or equivalent?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway has a controlled foreign corporation (CFC) regime, known as \u201cNOKUS\u201d<em>.<\/em> Under this regime, Norwegian private individuals and companies that, alone or together with other Norwegian taxpayers, own or control at least 50% of a foreign company domiciled in a low-tax jurisdiction are subject to Norwegian tax on their proportionate share of the foreign company\u2019s profit. This taxation applies regardless of whether the foreign company has distributed dividends to the Norwegian owners.<\/p>\n<p>There are important exceptions from CFC rules. CFC taxation may not apply if the foreign company is resident in an EEA state and meets the Norwegian substance requirements \u2013 meaning it is genuinely established and carries out genuine economic activities in an EEA state. Additionally, relief from CFC taxation may also be available under certain additional Norwegian tax exemptions or applicable tax treaties.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a transfer pricing regime?  Is there a \"thin capitalization\" regime?  Is there a \"safe harbour\" or is it possible to obtain an advance pricing agreement?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway has implemented transfer pricing rules in accordance with the OECD standard. Norwegian tax law requires that transactions between related parties be conducted at arm\u2019s length, and there are comprehensive documentation requirements for certain entities. The Norwegian tax authorities may adjust taxable income if the price in an intra-group transaction deviate from the arm\u2019s length principle.<\/p>\n<p>Norway does not have a formal thin capitalization regime with prescribed debt-to-equity ratios. However, the arm\u2019s length principle may be applied by the tax authorities in thin capitalization situations to assess whether the level of debt is commercially justifiable between related parties. In addition, Norway has interest deduction limitation rules.<\/p>\n<p>There is generally no &#8220;safe harbour&#8221; regime for transfer pricing in Norway. However, it is possible to apply for a bilateral Advance Pricing Agreement (APA) with the Norwegian tax authorities, to provide certainty regarding transfer pricing methods for future transactions. The tax treaties do not give taxpayers the right to demand an APA. It is up to the competent authorities of the countries involved to decide whether an APA should be entered into. However, under Article 25 (3) of the OECD Model Tax Convention, and in the same way as for a MAP, the treaty states have committed to endeavor to reach an agreement on how to apply the arm\u2019s length price in cases where there is a certain amount of doubt. Norway does not offer unilateral APAs.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a general anti-avoidance rule (GAAR) and, if so, how is it enforced by tax authorities (e.g. in negotiations, litigation)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway has implemented a general anti-avoidance rule (GAAR). The GAAR is applied in cases where tax advantages are obtained through transactions that have as their main purpose, or one of their main purposes, to achieve an improper tax benefit contrary to the purpose of tax legislation. The rule is applied on a case-by-case basis, considering the overall circumstances of the transaction.<\/p>\n<p>The rule was codified in 2020, without any significant changes compared to the previous non-statutory rule. The GAAR is applied by the tax authorities as part of the tax assessment and may be tried before the Norwegian courts. Negotiated settlements are not available.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a digital services tax? If so, is there an intention to withdraw or amend it once a multilateral solution is in place?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Currently, there is no special tax on digital services in Norway. Norway follows the BEPS initiative and has not introduced a digital services tax. There have been public reports and discussions regarding the implementation of such a tax, but Norway has so far chosen to await an international solution. If broad international consensus is reached, Norway is expected to adapt its approach accordingly.<\/p>\n<p>However, as part of its anti-base erosion measures, Norway has introduced a withholding tax on royalty payments made to foreign related entities located in low-tax jurisdictions.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Have any of the OECD BEPS recommendations, including the BEPS 2.0 two-pillar approach been implemented or are any planned to be implemented?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway has implemented several of the OECD BEPS recommendations and is actively working on the implementation of the BEPS 2.0 two-pillar approach. Many BEPS Action Points, such as interest deduction limitation rules, anti-hybrid rules, country-by-country reporting, and strengthened transfer pricing documentation requirements, have already been incorporated into Norwegian tax law.<\/p>\n<p>With effect from the income year 2024, Norway have introduced the \u201cTop-up Tax Act\u201d (<em>Nw: Suppleringsskatteloven<\/em>), which implements both the Income Inclusion Rule and the Domestic Minimum Top-Up Tax. This ensures a minimum tax rate of 15% for multinational enterprises, regardless of their geographical operations.\u00a0The Top-up Tax Act largely corresponds with the OECD\u2019s model rule.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How has the OECD BEPS program impacted tax policies?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The Norwegian Government is positive to implement the OECD BEPS program. This has resulted in several tax law amendments, including rules on the taxation of interest payments, amendments to the rules regarding the determination of tax residence and royalty payments, as well as the introduction of the Top-up Tax Act.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the tax system broadly follow the OECD Model i.e. does it have taxation of: a) business profits, b) employment income and pensions, c) VAT (or other indirect tax), d) savings income and royalties, e) income from land, f) capital gains, g) stamp and\/or capital duties? If so, what are the current rates and how are they applied?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, Norway generally adheres to the OECD Model. The Norwegian tax system outlines the taxation of the following:<\/p>\n<p><u>a. Business profits<\/u><\/p>\n<p>The corporate tax rate in Norway is 22%. Subject to taxation is the company&#8217;s net income, meaning that expenses necessary in generating income, such as operating costs and salaries, can be deducted and thus reduce the taxable profit.<\/p>\n<p>Share income is as a general rule tax exempt for corporate shareholders under the Norwegian participation exemption (see below under item 25). Withholding tax may be levied on outbound dividend payments at a rate of 25% (and on certain interest and royalty payments) but the tax rate may be reduced or protected pursuant to an applicable tax treaty.<\/p>\n<p>Norway has a limitation rule regulating intra-group interest payments.<\/p>\n<p><u>b. Employment income and pensions<\/u><\/p>\n<p>Employment income is subject to progressive tax rates up to approx. 47.4%, and is generally applied through employer withholding. All advantages and remuneration derived from employment are subject to employment taxation, including both cash and fringe benefits as well as any other forms of compensation.<\/p>\n<p>Employers are required to pay a contribution as part of the financing of the National Insurance Scheme. The employer&#8217;s contribution rate is up to 14.1%, which applies to most Norwegian businesses.<br \/>\n<u style=\"font-size: 1rem\"><\/u><\/p>\n<p><u style=\"font-size: 1rem\">c. VAT<\/u><\/p>\n<p>The general VAT rate levied on the supply of goods and services is 25%. Certain offerings are subject to a reduced VAT, e.g. food products (15%), passenger transport and hotel operations (12%).<br \/>\n<u><\/u><u><\/u><\/p>\n<p><u>d. Savings income and royalties<\/u><\/p>\n<p>Savings income, such as interest earned from bank deposits, and royalties received by resident taxpayers are generally included in ordinary income and therefore taxed at the standard income tax rate (22%). Royalties may in some cases be classified at business income.<\/p>\n<p>Norway does not generally impose withholding tax on interest or royalty payments made to non-residents. However, from 1 July 2021, a withholding tax of 15% applies to interest and royalty payments made to related parties resident in low-tax jurisdictions, subject to certain exemptions and the application of tax treaties. The withholding tax rate may be reduced or eliminated under an applicable double tax treaty.<\/p>\n<p><u>e. Income from land<\/u><\/p>\n<p>The municipalities may levy property tax on land and buildings. Further, Norwegian personal taxpayers are subject to wealth tax on the basis of their net wealth.<\/p>\n<p>Gains on sale of primary residence can be tax-exempt if certain ownership and residence conditions are met.<\/p>\n<p><u>f. Capital gains<\/u><\/p>\n<p>Capital gains are generally taxed as ordinary income at 22% for companies. For individuals, capital gains on shares are taxed at an effective rate of 37.84%, while other capital gains are taxed at 22%.<\/p>\n<p><u>g. Stamp and\/or capital duties<\/u><br \/>\nThere is generally no stamp duty, other than a stamp duty of 2.5% on transfers of real property. There are certain exceptions for certain transactions.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is business tax levied on, broadly, the revenue profits of a business computed in accordance with accounting principles?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Corporate tax is levied on the taxable profits of a business, which is broadly based on accounting principles but subject to several adjustments as specified in tax legislation. These adjustments include differences in the treatment of depreciation of assets, tax exemption for capital gains and dividends on shares. Additionally, there are special tax rules for loss carry-forward, group contributions and thin capitalization\/interest limitation. As a result, the taxable profit can differ substantially from the accounting profit reported in the financial statements.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are common business vehicles such as companies, partnerships and trusts recognised as taxable entities or are they tax transparent?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Norwegian companies (Ltd., (<em>Nw: AS\/ASA<\/em>)) are generally recognized as taxable entities, while Norwegian partnerships (<em>Nw: ANS\/DA<\/em>) are considered transparent for Norwegian tax purposes. Thus, the owners of a transparent partnership will typically be taxed based on a net calculation method where the partnership income is consolidated with the corporate income of the owner.<\/p>\n<p>Norwegian law does not recognize the principle of a trust or any split between legal and beneficial ownership. Consequently, the tax treatment of a trust and the determination of who is regarded as the beneficial owner of its assets must be assessed under the standard tax rules, including the substance-over-form doctrine. As a result, trusts are often fully disregarded for Norwegian tax purposes, meaning that either the beneficiary or the settlor is considered the direct beneficial owner of the trust&#8217;s assets and income.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is liability to business taxation based on tax residence or registration?  If so, what are the tests?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>As a general rule, a company incorporated in Norway will be liable to Norwegian tax on its worldwide income pursuant to the global revenue principle. In addition, a foreign business may also become subject to Norwegian tax on business conducted or effectively managed from Norway (limited tax liability). This is determined based on a combination of factors, such as place of management, location of the Board, and business premises.<\/p>\n<p>However, this tax liability to Norway may be protected or limited if the company in question is regarded as resident in a foreign jurisdiction under an applicable tax treaty.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any favourable taxation regimes for particular areas (e.g. enterprise zones) or sectors (e.g. financial services)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Norway does not have enterprise zones in the traditional sense. However, employer\u2019s social security contributions may be reduced based on the business&#8217;s geographic location, based on a scheme approved by the EFTA Surveillance Authority (ESA) as state aid pursuant to the EEA-agreement. For individuals, wealth tax and property tax may vary between municipalities, as these taxes are levied locally by the municipalities.<\/p>\n<p>Norway offers a tonnage tax regime for qualifying shipping companies, allowing them to pay tax based on the tonnage of their fleet rather than actual profits. In addition, Norway has an R&amp;D tax incentive scheme (\u201cSkatteFUNN\u201d), which provides tax deductions for expenses related to research and development activities and is available across all sectors.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any special tax regimes for intellectual property, such as patent box?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Norway does not have any special tax regimes concerning intellectual property.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is fiscal consolidation permitted? Are groups of companies recognised for tax purposes and, if so, are there any jurisdictional limitations on what can constitute a tax group? Is there a group contribution system or can losses otherwise be relieved across group companies?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Fiscal consolidation is not permitted as such. Instead, Norwegian companies that are part of the same corporate group are entitled to consolidate their taxable profits and\/or deductible losses (and tax losses carried forward) through group contributions. A corporate group exists where a company, directly or indirectly, holds more than 90% of the shares and votes in another company as of 31 December in the relevant fiscal year.<\/p>\n<p>While it is possible to consolidate profits and losses between companies domiciled within the EEA, this is subject to strict conditions. As a result, this option is of limited practical relevance and is rarely utilized in practice.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any withholding taxes?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Norway has a general domestic rule imposing a 25% withholding tax on dividends paid to foreign shareholders. There are also specific rules imposing withholding tax on certain interest and royalty payments made to entities resident in low tax jurisdictions. However, any applicable withholding tax may be protected pursuant to a relevant tax treaty between Norway and the recipient&#8217;s country.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any environmental taxes payable by businesses?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, there are several environmental taxes payable by businesses in Norway. These include taxes on the emission of CO2, NOX (nitrogen oxides) and the extraction and production of oil and condensate. There are also special taxes on specific products, such as single-use plastic packaging. The purpose of these taxes is to incentivize reduced environmental impact and promote sustainable business practices.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is dividend income received from resident and\/or non-resident companies taxable?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Dividend income (and capital gains) received by Norwegian corporate shareholders from companies tax resident in Norway or within the EEA is generally exempt from taxation (subject to a substance test in the EEA) under the Norwegian participation exemption.<\/p>\n<p>However, dividends received from an EEA company with a shareholder ownership below 90%, 3% of the dividend amount is taxable at the standard corporate tax rate of 22%, resulting in an effective tax rate of 0.66% on the total dividend.<\/p>\n<p>Dividend income from companies tax resident outside the EEA is also tax exempt for a Norwegian corporate shareholders, provided that i) the shareholder owns more than 10% of the shares and 2) the ownership period exceeds two years. Conversely, dividend income from companies in low-taxation jurisdictions is generally not tax exempt pursuant to Norwegian domestic tax law.<\/p>\n<p>Dividend income from shares that do not qualify for Norwegian participation exemption is subject to tax at a flat rate of 22% for Norwegian corporate shareholders.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the advantages and disadvantages offered by your jurisdiction to an international group seeking to relocate activities?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are several advantages to relocating business activities to Norway. The country offers a well-developed, generally predictable, and transparent legal and regulatory environment, which is attractive for international business operations. Norway also boasts a highly educated and skilled workforce, a developed and stable infrastructure, low corruption rates, and a robust digital infrastructure equipped for efficient operations.<\/p>\n<p>Additionally, Norway employs a participation exemption method, allowing companies to receive dividends and capital gains from qualifying shareholdings tax-free. Furthermore, Norway has an extensive network of double taxation treaties, which helps prevent double taxation and provides a range of benefits for international groups operating across borders.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">4048<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/113676","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/my.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=113676"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}