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Introduction

Norway’s tax system is characterized by its transparency and adherence to international standards. As a country with no foreign exchange controls, it fosters an open environment for both domestic and foreign businesses. The accounting standards in use are Norwegian Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), requiring statutory accounts to be prepared annually.

Key Business Entities

In Norway, businesses can be structured as:

  • Public Limited Company (ASA)
  • Private Limited Company (AS)
  • Limited Partnership (KS)
  • General Partnership (ANS/DA)
  • Branch of a Foreign Company (NUF)
  • Sole Proprietorship

Corporate Taxation

Tax Rates

  • Corporate Income Tax Rate: The standard rate is 22%
  • Branch Tax Rate: Foreign branches operating in Norway are also taxed at 22%
  • Capital Gains Tax Rate: Generally, capital gains are taxed at 22%, with a notable exception for gains from the sale of shares in certain conditions.

Residence Rules

  • Resident Companies: Companies incorporated in Norway or effectively managed from Norway are treated as residents and taxed on their worldwide income.
  • Non-Residents: These entities are only taxed on income sourced within Norway.

Taxable Income

Corporate income tax applies to a company’s profits, which include:

  • Business and trading income
  • Passive income (e.g., dividends, interest)
  • Capital gains (with broad exemptions for capital gains on shares)

Key Developments

In 2024, Norway has aligned its corporate tax regulations with the OECD’s Pillar Two initiative, which seeks to establish a global minimum corporate tax rate. This means that multinational groups with revenues exceeding EUR 750 million will be subject to a minimum effective tax rate of 15%. The implementation of the Income Inclusion Rule (IIR) and the Qualified Domestic Minimum Top-up Tax (QDMTT) will affect accounting periods starting after December 31, 2023.

Dividends and Capital Gains

  • Dividends: A significant aspect of Norwegian tax law is the participation exemption, which allows for a 97% exemption on dividends received from other resident companies or companies based in the European Economic Area (EEA), provided certain conditions are met (e.g., real business activities).
  • Capital Gains: Generally, capital gains on the sale of shares are exempt from taxation, especially if the shareholder has held a significant interest (at least 10%) for two years. However, there are specific rules for companies based in low-tax jurisdictions.

Losses

Companies in Norway can carry forward losses indefinitely, which can be beneficial for tax planning. Liquidation losses can be carried back for two years, offering further flexibility in managing taxable income

Compliance Requirements

  • Filing:Companies are required to file electronic tax returns by May 31 of the year following the tax year.
  • Advance Payments:Corporations must make advance tax payments twice a year, usually in February and April.

Individual Taxation

Tax Rates

  • Personal Income Tax Rates
    • Up to NOK 208,049: 0%
    • NOK 208,050 – 292,849: 1.7%
    • NOK 292,850 – 669,999: 4%
    • NOK 670,000 – 937,899: 13.6%
    • NOK 937,900 – 1,349,999: 16.6%
    • Over NOK 1,349,999: 17.6%
  • Capital Gains Tax Rate: The general capital gains tax rate is 22%, but gains on securities can result in an effective rate of 37.84% due to a multiplier effect.

Residence Rules

An individual is considered a permanent resident of Norway if they stay in the country for more than 183 days within a 12-month period or 270 days over a 36-month period. It’s important to note that non-residents are taxed only on their Norwegian-source income.

Taxable Income

Taxable income encompasses a wide range of sources, including:

  • Salaries and wages
  • Dividends and interest
  • Income from real property
  • Partnership income

The combined municipal and national tax rate is 22% on net income, supplemented by progressive rates on personal income.

Deductions and Allowances

Norwegian tax law provides several deductions to minimize taxable income, including:

  • A standard deduction for incidental personal expenses of up to 46% of salary, capped at NOK 104,450
  • A personal allowance of NOK 88,250
  • Unlimited deductions for interest paid on debt

Compliance Requirements

Filing Deadline: Tax returns must be filed by April 30 of the year following the tax year for individuals who do not operate a personal business.

Withholding Tax

Rates for Non-Residents

  • Dividends: Generally subject to a 25% withholding tax, but this may be reduced under applicable tax treaties.
  • Interest: A withholding tax of 15% applies to certain payments made to related companies in low-tax jurisdictions.
  • Royalties: Similar treatment as interest, with potential for a 15% withholding tax.

Value Added Tax (VAT)

Rates

  • Standard Rate: 25%
  • Reduced Rates: 15% for food and drinks, 12% for transport and accommodation services.

Registration and Filing

Businesses exceeding an annual turnover of NOK 50,000 must register for VAT. There are six filing periods per year (every two months), ensuring regular compliance

Other Taxes

Social Security Contributions

Employees contribute 7.8% of gross income, while employers’ contributions vary by region, typically ranging from 0% to 14.1%

Wealth Tax

Individuals face a 1% wealth tax on capital exceeding NOK 1.7 million and 1.1% on wealth over NOK 20 million.

Additional Taxes

  • Stamp Duty: A 2.5% stamp duty on property transfers.
  • No Inheritance or Estate Tax: Norway does not impose these taxes, which can be attractive for estate planning.

Anti-Avoidance Rules

Norway’s tax regulations include robust anti-avoidance measures to ensure compliance and fair taxation:

Transfer Pricing

Intercompany transactions must follow the arm’s length principle, and companies must maintain appropriate documentation to support pricing arrangements.

Interest Deduction Limitations

Net interest expense deductions are capped at 25% of adjusted tax EBITDA, with specific rules for group companies.

Controlled Foreign Companies (CFC)

Norwegian residents who control foreign companies in low-tax jurisdictions may be subject to CFC rules, ensuring income is taxed appropriately.

Conclusion

Norway’s tax landscape is dynamic and adheres to international best practices. As businesses and individuals navigate this system, staying informed about recent developments, compliance requirements, and available deductions can lead to effective tax management. With the ongoing implementation of global tax standards, including the OECD’s initiatives, it’s crucial for entities operating in Norway to adapt and plan strategically for the future.