Norway

Last modified: 28/01/2025 21:14

Corporate taxation

	Rate
Corporate income tax rate	22%
Branch tax rate	22%
Capital gains tax rate	22%
Certain companies within the financial sector	25%

Residence: A company is tax resident in Norway if it is incorporated in Norway under Norwegian company law, or its effective management and control is in Norway.

Basis: Resident companies are taxed on their worldwide income. Non-resident companies are taxed on business performed and/or on property located in Norway. Branches are taxed in the same way as subsidiaries.

Taxable income: Income tax is imposed on a company’s net profits including business/trading and passive income and capital gains. Foreign-source income is generally included in taxable income, with credit for foreign taxes.

Significant local taxes on income: None

Alternative minimum tax: No

Taxation of dividends: Dividends to a Norwegian company received from EU/EEA countries are as a main rule tax-exempt. Dividends in qualifying participations in companies outside the EU/EEA are also exempt subject to more detailed rules. Dividends from low-tax jurisdictions outside the EU/EEA are not exempt.

Capital gains: Gains received from shares in companies within the EU/EEA are as a main rule tax-exempt. Gains from qualifying participations in companies outside the EU/EEA are also exempt subject to more detailed rules. Dividends from low-tax jurisdictions outside the EU/EEA are not exempt, and losses are not deductible.

Losses: Losses in a business are deductible subject to detailed rules. Losses may be carried forward for an indefinite period. Debt forgiveness reduces a loss carried forward proportionally. There is an anti-avoidance rule that can affect the company’s loss carried forward in change of control situations etc.

Foreign tax relief: Foreign-source income is generally taxable subject to a credit for the tax paid abroad based on detailed rules.

Participation exemption: Yes, see above under ‘Taxation of dividends’ and ‘Capital gains’

Holding-company regime: There is no holding company regime.

Tax-based incentives: There is a scheme for refund of tax for certain approved R&D projects. The tax is “refunded” even if the company has not paid tax.

Group relief/fiscal unity: There is no consolidated filing. Group relief is managed by rules for transferring taxable profits from one group company to another.

Small company/alternative tax regimes: No

Corporate taxation: compliance

Tax year: The tax year follows the calendar year.

Consolidated returns: No

Filing and payment: Filing of the tax return is due 31 May the following year. Taxes are paid 15 February and 15 April the following year. The first payment is made on a projection.

Penalties: All enterprises that are declarants for either their own circumstances or those of others can receive an enforcement fine if they fail to submit mandatory information by the relevant deadline.

Rulings: Binding rulings can be obtained. It is also possible to enter into APAs – “Advanced Pricing Agreements” – with the Tax Authorities.

Taxation of individuals

Personal income tax – Bracket tax

The bracket tax for personal taxpayers is calculated on personal income. Personal income is salary income and other  incomes which replace salary income, such as sick pay, work assessment allowance, disability benefit and pension.

Bracket tax consists of five steps. There is no bracket tax on the first NOK 217,400 of the personal income. 

The bracket tax and the tax on ordinary income together gives a maximum effective tax rate on salary of 47.4% and 50.6% on self employd in 2025.

	Income between NOK 0 – 217,400	No bracket tax
Step 1	Income between NOK 217,401 – 306,050	1.7%
Step 2	Income between NOK 306,051 – 697,400	4.0%
Step 3	Income between NOK 697,401 – 942,400	13.7%
Step 4	Income between NOK 942,401 – 1,410,750	16.7%
Step 5	Income from and including NOK 1,410,751	17.7%

Residence: Any person who: a. over one or more periods spends more than 183 days in Norway over the course of any twelve-month period; or b. over one or more periods spends more than 270 days in Norway over the course of any thirty-six-month period; is deemed to be resident in Norway, but not until the tax year in which his or her stay in Norway exceeds the number of days mentioned in a and b, respectively.

Taxable income: Resident individuals are taxed on their worldwide income. Non-residents are taxed on Norwegian employment income, business profits and profits attributable to Norwegian immovable property.

Capital gains: The capital gains rate on income from shares in limited liability companies and partnerships, and financial instruments with shares as the underlying object (such as options, warrants etc) is 37.84% for individuals. The ordinary rate for capital gains is 22%.

Deductions and allowances: For salary, there is a minimum standard deduction of 46% in the ordinary income, limited to NOK 92.000 in 2025. Other deductions may also apply.

Foreign tax relief: The main rule is that a resident taxpayer is taxed on the worldwide income. There are detailed rules for credit for taxes paid in the state of source for the income.

Taxation of individuals: compliance

Tax year: The tax year follows the calendar year.

Filing and payment: On salary, tax is withheld and paid in to the Tax Authorities monthly by the employer. Wealth tax and tax on other income is paid in four instalments during the year. The date for filing the tax return for individuals is 30 April. Many individual taxpayer will have a prefilled tax return availuable. Foreign workers who are new to Norway are normally automatically included in a voluntary tax scheme with 25% withholding tax on salary when they apply for a tax deduction card. In this tax scheme, a fixed percentage tax is paid, which the employer deducts from the salary.

Penalties: The ordinary rate for penalty tax is 20%, where the taxpayer has provided incorrect or insufficient information of his tax affairs.

Rulings: A taxpayer can request binding advance rulings from the Tax Administration regarding the tax or VAT consequences of planned actions.

Withholding taxes

Withholding tax (WHT) is paid on dividens, interest and royalties from Norwegian sources under local law.

Resident: N/A

Non-resident: 25 / 15 / 15

The 15% WHT rate applies on the gross payment on interest, royalties, and certain lease payments to related parties resident in low-tax jurisdictions.

The rates may be lower due to provisions in a tax treaty or for companies situated within the EEA area.

Individuals may be liable to pay withholding tax on pensions and disability benefits if they are not resident in Norway for tax purposes.

Branch remittance tax: Branch income is taxed at the corporate rate of 22% (25% for certain entities within the financial sector), i.e. the same rate as Norwegian companies.

Anti-avoidance legislation

Transfer pricing: Enterprises may have an obligation to disclose controlled transactions/dealings and outstanding accounts as a separate topic in the tax return. In addition, enterprises may have an obligation to prepare and submit mandatory transfer pricing documentation. There are local rules, however, documentation that follows the OECD standards, is accepted.

Interest restriction: Rules have been laid down which mean that a company in a group can have an interest deduction cut off under the Norwegian interest limitation rules. However, a full or partial interest deduction may be granted if one of the very detailed exemption rules applies.

Controlled foreign companies: Norwegian taxpayers who are owners of a Controlled Foreign Company, CFC (“NOKUS”) will be taxed on a share of the company’s taxable profits. A CFC is a company that is domiciled in a low-tax country, i.e. have an effective tax rate of less than 2/3’s of the effective Norwegian rate, and where at least 50 per cent of the company is owned or controlled by Norwegian taxpayers.

Hybrid mismatches: Norway has rules that restricts hybrid mismatches. Dividends covered by the Norwegian participation exemption method are not considered tax-free if the distribution is deductible by the distributing company. Withholding tax on dividends, interest, and royalty is also implemented to curb tax avoidance.

Exit taxes: Norway has extensive rules for exit tax for individuals and companies. When assets or liabilities that have been in the Norwegian taxation area are moved out of Norwegian taxation, the withdrawal is taxed. This applies even if what is withdrawn does not change owner. There are also deductions for losses. Individuals are exit taxed on emigration for the increase in value of shares and financial instruments with shares as the underlying object. There are different options for deferral or instalment payment of the tax. The tax does not lapse even if the taxpayer keeps the assets intact. Companies incorporated in Norway that move and/or withdraw assets or liabilities from the Norwegian taxation area are taxed. The same applies to taxpayers resident abroad with limited tax liability in Norway. Norwegian owners of shares that are subject to CFC taxation are taxed if the Norwegian ownership interest falls below 50%. Such a reduction in the ownership stake means that the company can no longer be taxed on CFCs with those who are Norwegian tax residents.

Social security contributions

	Employer	Employee
	Rate (%)	Rate (%)
Band 1	0	0
Band 2	0	0
Band 3	0	0

Other taxes

Other: Tax on resource rent industries Petroleum 71,8 pst. Effective marginal rate is 78% Hydropower 57,7 pst. Aquaculture 32,1 pst. Wind power 32,1 pst.