ey.com/globaltaxguides
Oslo GMT +1
EY Street address:
Mail address: Oslo Atrium
P.O. Box 1156 Sentrum Dronning Eufemias gate 6 Oslo Atrium 0191 Oslo N-0107 Oslo Norway Norway
Executive contacts
Johan A. Killengreen +47 98-20-63-75
Email: johan.killengreen@no.ey.com
Pål André Johansen +47 98-20-62-95 Email: pal.a.johansen@no.ey.com
Trond Olsen +47 90-82-34-52
Email: trond.olsen@no.ey.com
Helen Christensen +47 51-70-66-52 (resident in Stavanger) Email: helen.christensen@no.ey.com
Immigration contact
Torkil Westergaard Altern +47 93-40-90-18 Email: torkil.w.altern@no.ey.com
A. Income tax
Who is liable. Individuals resident in Norway are subject to tax on their worldwide income. Nonresidents are taxable on Norwegiansource income only. Wages and remuneration may be considered Norwegian-source even if an employer has no permanent establishment in Norway.
Individuals present for a period or periods exceeding in aggre gate 183 days in any 12-month period or 270 days in any 36-month period are considered to be resident for tax purposes. After emigrating from Norway, an individual continues to be considered a resident for tax purposes if the individual, or some one closely related to him or her, maintains a home in Norway. After emigrating from Norway, an individual who does not main tain a home in Norway is considered to be a resident if the indi vidual stays in Norway for more than 61 days per income year.
Notwithstanding the conditions mentioned above, an individual who has been resident in Norway for more than 10 years is con sidered to be resident for tax purposes in the three-year period after emigration and for as long as he or she maintains a home in Norway or stays in Norway for more than 61 days during a year.
Special rules may apply to individuals working on the Norwegian Continental Shelf.
Income subject to tax. The taxation of various types of income is described below.
Employment income. Taxable income generally includes salaries and wages, bonuses, directors’ fees, benefits in kind, annuities and pensions, whether the benefit is earned over a period of time,
occasionally or on a single occasion. Most allowances and fringe benefits are considered taxable income.
Nonresidents are subject to tax at various rates on income earned from work carried out in Norway and on wages earned on ships registered with the Norwegian common shipping register.
Self-employment and business income. Residents are subject to tax on worldwide self-employment and business income. Non residents are subject to tax if they engage or participate in business or other economic activities carried on or administered in Norway. Further more, persons with assets in Norway in the form of real property or tangible assets are subject to tax on income derived from such assets at the ordinary 22% rate described in Rates. Special rules may apply to shipping activities.
Partnerships are subject to so-called net assessment. The partnership model applies to general partnerships (ANS), limited partnerships (KS), silent partnerships (IS) and shipping partnerships (Partsrederier). Effective from 2016, new regulations were introduced for distributed income to personal shareholders and participants in partnerships. As a result of the reduction of the corporate tax rate from 23% to 22%, the basis for the calculation of distributed income is increased by an adjustment factor of 1.44 (2021 rate).
For 2021, such partnership taxation ensures the same level of taxation on both retained and distributed profits as in limited companies. The maximum marginal tax rate for distributed income is 46.7% for 2021.
The partnership model applies to all partners, regardless of whether the partners are active. However, partners, other than partners who are individuals, are not subject to additional taxa tion at distribution under the exemption method.
For self-employed individuals, all business profits exceeding a risk-free interest on the capital invested are taxed as personal income.
Taxable personal income serves as the basis for levying both personal income tax (step tax) at a rate of up to 16.2% and the social security contribution at a rate of 11.4%. It also entitles an individual to pension points in the social security system.
Nonresidents are also subject to tax at the same rates that apply to residents on the following amounts:
• Income from, and capital invested in, activities carried on or managed either in Norway or on the Norwegian Continental Shelf
• Income derived from providing employees for principals who are carrying on activities in Norway
• Income derived from, and capital invested in, real and movable property located in Norway
• Fees paid to foreign entertainers and artists for performances in Norway
Nonresidents may also be subject to Norwegian taxes if they participate as general partners or limited partners in businesses carried on in Norway. For example, a leasing business with
property in Norway is taxable, even if the activity is not carried out through a fixed place of business in Norway.
Investment income. Interest, rental income and royalties are sub ject to tax with other ordinary income at a rate of 22%.
For dividends received by shareholders who are individuals, a shareholders’ model has been introduced. Under the shareholders’ model, dividends exceeding a risk-free return on the investment (the cost base of the shares) are taxed as general income when distributed to individual shareholders. The part of the dividend that does not exceed a risk-free return on the investment is not taxed in the hands of the shareholder. If the dividend for one year is less than the calculated risk-free interest, the tax-free surplus amount can be carried forward to be offset against dividends distributed in a subsequent year or any capital gain derived from the alienation of the shares on which the dividend is paid. In addi tion, an adjustment factor of 1.44 is introduced for dividends in 2021.
The shareholders’ model applies to dividends received by Norwegian individuals and to individuals resident in other European Economic Area (EEA) states who are subject to Norwegian withholding tax.
Effective from 2021, dividends are multiplied by an adjustment factor of 1.44, and the adjusted basis is then taxed as ordinary income at a rate of 22%. As a result, the effective tax rate for dividends is 31.68%.
Nonresidents are subject to a 22% withholding tax on dividends paid by Norwegian companies, unless a lower treaty rate applies. Withholding tax is not imposed on interest and royalties paid to nonresidents.
Directors’ fees. Nonresident and resident directors are taxed on directors’ fees from Norwegian companies. Directors’ fees are taxed in the same manner as employment income.
Optional simplified tax regime for foreign workers. From 2019, a simplified tax regime, Pay As You Earn (PAYE), for foreign workers is introduced to the Norwegian tax system. The simplified tax regime is optional; that is, the individual can choose to be part of the regular tax regime, as described above, or the sim plified tax regime. In the simplified tax regime, employment income is taxed based on a gross method with a fixed rate of 25% (including the employee social security contribution). If an A1/ Certificate of Competency form is provided, an individual can be exempt from social security contributions of 8.2%, resulting in a fixed rate of 16.8%. No deductions from the tax base are allowed. In addition, the tax is determined and assessed as final on an ongoing basis through the employer’s tax withholding and report ing to the tax administration.
To be eligible for the simplified tax regime, the individual must be considered a nonresident or first-year resident according to Norwegian law. The regime does not apply to offshore workers and foreign seafarers. In addition, the annual employment income must be below a certain threshold. Other conditions may apply; therefore, a case-by-case evaluation is required.
Individuals who are part of the simplified tax regime do not have an obligation to submit an annual individual tax return (see Section D).
Taxation of employer-provided stock options. Stock options pro vided by employers to employees are taxed at the date of exercise as income from employment.
The taxable value at the date of exercise is the fair market value of the shares at the date of exercise, less the exercise price and any other costs incurred by the employee related to the grant of the options or the conversion of the options to shares.
Capital gains and losses. Capital gains derived from disposals of business assets, including real property, are subject to ordinary income tax at a rate of 22%.
Effective from 2020, capital gains from the disposal of shares are multiplied by an adjustment factor of 1.44, and the adjusted basis is then taxed as ordinary income at a rate of 22%. As a result, the effective tax rate for capital gains from the disposal of shares is 31.68%.
Capital losses derived from disposals of shares are deductible against ordinary income (22%). However, the taxable gain may be reduced by any unused tax-free amount with respect to divi dends received (see Investment income).
The gain derived from the sale of a personal residence is not subject to tax if the owner lived in the residence for at least 12 months during the 24 months before the sale. Otherwise, the gain derived from the sale of a private residence is subject to ordinary income tax, and losses are deductible from ordinary income.
Nonresidents are taxed on capital gains from capital assets located in Norway only.
Exit tax. Norway imposes an exit tax on unrealized profits on shares or share units in Norwegian or foreign companies, including units in securities funds and stock options. The exit tax applies only to profit exceeding NOK500,000.
Individuals who have been resident in Norway for tax purposes are taxed on profits as if the shares, units, options and similar instruments were realized on the last day the individual was con sidered a tax resident of Norway for either domestic or tax treaty purposes. The deemed gain after an adjustment of 1.44 is subject to capital gains tax at the normal rate of 22%.
For individuals who have resided in Norway for more than 10 years and were born in Norway, the profit is calculated as the spread between the original cost price of the asset and the market value at the time of emigration. However, individuals who have resided in Norway for less than 10 years may choose to use the market price at the time he or she became tax resident in Norway instead of the actual cost basis. However, this rule applies only to shares and share units owned by the individual when he or she took up residence in Norway.
The exit tax ceases to apply if the gain on the assets is not actu ally realized within five years after the emigration (or in the case of stock options, if the options are not exercised in the fiveyear period). The taxable profit can also be reduced if the actual sales price was lower than the value of the shares at the date of emigration.
It is possible to defer the payment of the exit tax until actual realization of gain takes place. To achieve this deferral, the tax payer needs to furnish adequate security for the payment obliga tion or move to a state within the EEA with which Norway has entered into an agreement for the exchange of information and assistance with recovery of taxes.
Deemed losses on emigration are also calculated using the same rules (that is, on shares sold within five years of emigration), and any loss is offset against gains chargeable at the capital gains rate of 22%. However, the loss may be excluded on emigration out side the EEA, and no loss is granted as a result of step-up of the historic cost price.
In general, strict documentation requirements apply at the time of emigration and for the following five years. If the deemed profit is less than NOK500,000 and, consequently, no exit tax applies, the taxpayer is still required to report the unrealized profit to the Norwegian tax authorities.
Deductions
Deductible expenses. A 10% standard deduction can be claimed by foreign seafarers and shelf workers because they cannot be included in the new regime for foreign workers (see Optional simplified tax regime for foreign workers).
Personal allowances. In calculating ordinary income tax for 2021, individuals are allowed a standard minimum allowance of 46% of gross compensation, with a maximum of NOK106,750 and a minimum of NOK4,000. This allowance is reduced proportion ately if the individual is taxable in Norway for only part of the fiscal year.
Business deductions. To be deductible for tax purposes, items must be included in the statutory financial statements. In princi ple, all expenses for earning, securing or maintaining income, with the exception of gifts and entertainment expenses, are deductible. Valuation and depreciation rules for individuals earn ing self-employment or business income are the same as those for corporations.
Rates
Personal income tax. Personal income tax (step tax) is levied on income from employment and pensions, and no deductions are allowed. The step tax rates for 2021 are set forth in the following table.
Taxable income
Ordinary income tax. A 22% ordinary income tax (county munic ipal tax, municipal tax and state tax) is levied on taxable net income from all sources after taxable income is reduced by NOK52,450 for individuals both with and without dependents. The personal allowance in tax Class 2 for individuals with depen dents was terminated from 1 January 2018.
If an individual is taxable in Norway for part of a fiscal year only, the income brackets and excludable amounts are reduced propor tionately.
Relief for losses. In general, losses may be carried forward for 10 years.
B. Other taxes
Wealth tax. A municipal and national wealth tax is levied at a rate of 0.85% on taxable net assets exceeding NOK1,500,000.
Inheritance and gift taxes. Effective from 1 January 2014, inheri tance and gift taxes no longer apply in Norway.
C. Social security
Contributions. Employers and employees, as well as selfemployed individuals, must make social security contributions. Contributions are payable on all taxable salaries, wages and allow ances and, for self-employed individuals, on personal income.
For employees, contributions are withheld by employers together with income tax, and the total amount is paid to the tax authori ties. Employers’ contributions, payable bimonthly, are deductible for income tax purposes. Employees’ and self-employed individuals’ contributions are not deductible. The 2021 contribution rates are 8.2% of salary for employees and 11.4% for selfemployed individuals. For 2021, the employer’s contribution is 14.1%. In certain municipalities, the employer rate is lower.
Expatriates and foreign employers of employees working in Nor way are subject to these contributions if an exemption (or reduc tion) is not available under a social security convention between Norway and the country where the expatriate or the employer is domiciled.
Totalization agreements. To provide relief from double social security taxes and to assure benefit coverage, Norway has entered into social security agreements with the following jurisdictions.
Australia France (a)
Austria (a) Germany (a)
Poland (a)
Portugal (a)
Belgium (a) Greece (a) Romania (a) Bosnia and Hungary (a) Serbia and
Herzegovina Iceland (a) Montenegro Bulgaria (a) India
Slovak
Canada (b) Ireland (a) Republic (a)
Chile Israel Slovenia (a)
Croatia Italy (a)
Spain (a)
Cyprus (a) Latvia (a) Sweden (a)
Czech Liechtenstein (a) Switzerland Republic (a) Lithuania (a) Turkey
Denmark (a)
Estonia (a)
Finland (a)
Luxembourg (a)
Malta (a)
Netherlands (a)
United
Kingdom (a)
United States
(a) EEA countries’ agreement. European Union Regulation 883/2004 was imple mented 1 June 2012 in Norway. (b) Separate agreement with Quebec.
D. Tax filing and payment procedures
Income tax and wealth tax on net taxable assets are assessed for a fiscal year ending 31 December. For most individuals resident in Norway who do not have trading income, annual tax returns must be submitted by 30 April in the year following the income year. An extension of one month may normally be obtained. For self-employed individuals, annual tax returns filed electronically must be submitted by 31 May.
Individuals who are self-employed or who have income from sources other than salaries, wages and similar compensation, re ceive from the tax authorities an individual estimate of taxes to be paid during the tax year. These estimated taxes are due in four equal installments on 15 March, 15 May, 15 September and 15 November. Assessments have normally been made in the third quarter of the year following the income year. Beginning with 2011, the Norwegian authorities announce the assessments in four different months. An individual may receive an assessment in June, August, September or October. At the time of assess ment, an individual receives a tax computation showing total as sessed taxes compared to taxes paid. Any amount of tax overpaid is refunded to the taxpayer, and any tax due is payable in two equal installments.
Taxes are withheld by employers from salaries, wages and other remuneration paid to employees. Nonresident employees who do not provide their employers their tax-deduction cards issued by the tax authorities are subject to 50% withholding. Employees who present their tax-deduction cards are eligible for the reduced rate specified in the cards. The withholding taxes are preliminary payments and are credited to the taxpayers in their tax assess ments.
Individuals who are part of the simplified tax regime are not required to file an annual individual tax return.
E. Tax treaties
Norway’s double tax treaties generally follow the Organisation for Economic Co-operation and Development (OECD) model. Norway has entered into double tax treaties with the following jurisdictions.
Albania Greenland Portugal
Argentina Hungary Qatar Australia Iceland Romania Austria India Russian Federation
Azerbaijan Indonesia Senegal Bangladesh Ireland Serbia
Barbados Israel Sierra Leone Belgium Italy Singapore
Benin Jamaica Slovak Republic
Bosnia and Japan Slovenia
Herzegovina Kazakhstan South Africa
Brazil Kenya Spain
Bulgaria Korea (South) Sri Lanka
Canada Latvia Sweden
Chile Lithuania Switzerland
China Mainland Luxembourg Tanzania
Côte d’Ivoire Malawi
Thailand
Croatia Malaysia Trinidad and Cyprus Malta
Tobago
Czech Republic Mexico Tunisia Denmark Morocco Turkey
Egypt Nepal Uganda Estonia Netherlands Ukraine
Faroe Islands Netherlands United Kingdom
Finland Antilles United States
France New Zealand Venezuela
Gambia Pakistan Vietnam Germany Philippines Zambia Greece Poland Zimbabwe
F. Immigration regulations
All foreign nationals, except EEA nationals, are required to obtain a work permit before entering the country. Entrance for short-term visits, tourist visits, family visits, business trips and certain other purposes for a duration up to three months is allowed in accordance with the applicable visa.
All foreign nationals (except Nordic nationals) who wish to enter Norway must also carry valid passports or other identification officially recognized as valid travel documents.
Norway entered into the Schengen Agreement on 25 March 2001. Under the agreement, no passport controls apply to pass borders within the Schengen area. Passport controls will apply to pass the Schengen area’s outer border, both to enter and depart the area. Non-EEA nationals are subject to extended controls, that is, a search of the Schengen Information System to determine whether the individual is registered with a denial to enter. As a general rule, under the agreement, visas issued by Norwegian authorities are valid to enter the entire Schengen area. Likewise, visas issued by other Schengen countries are valid to enter Norway.
Norway has visa-free arrangements for short-term visitors with 64 jurisdictions, in addition to all of the EU/EEA countries. Citizens of these countries are not required to obtain visas to enter Norway for short-term visits. Other exceptions to the visa requirement may exist. For further details, contact a Norwegian Foreign Service mission or the Directorate of Immigration (UDI).
G. Work permits
Foreign nationals for whom a visa is required must apply for a visa or residence permit in order to stay or work in Norway for any length of time. Once the permit a granted, visa-required nationals will also be issued an entry visa.
Residence permits are granted only if a particular reason for living or working in Norway exists, such as a work assignment, a trainee
assignment, cultural exchange or family immigration. Any person who applies for a work permit must receive a concrete offer of employment in advance. The applicant must also have adequate income.
Nordic citizens do not need a residence permit to reside or work in Norway.
EU/EEA nationals do not need to apply for residence permits in Norway. They can do an advance registration online and attend an appointment with the authorities in person on arrival in Norway. EU/EEA nationals need to register in Norway only if they intend to work and stay in Norway for more than three months.
Work permit application process. The residence permit application must generally be submitted from abroad before an individual enters Norway. An application can also be submitted through a power of attorney by a third party in Norway. A first-time work permit must be granted before entry. However, for individuals holding a legal immigration status in Norway, such as visa-free travelers and skilled workers, a residence permit application can be submitted after entry. If they apply in Norway, they can submit the application either to the police district where they live or at a service center for foreign workers.
Prior to submission, all applications must be registered through the Application Portal, and the relevant documents can be uploaded electronically to the immigration authorities. The Foreign Service mission can provide information about docu ments that must be included with the application.
The Foreign Service mission sends the work or residence permit application to the Directorate of Immigration, which decides whether to grant the permit. After the application is considered, the applicant is informed of the results by the Foreign Service mission in the applicant’s home country or via a third party in Norway with a power of attorney. Foreign nationals from certain countries are requested by the police to complete a mandatory and free tuberculosis test within the first weeks after arrival in Norway.
Non-EEA nationals with an EEA employer. A non-EEA national may have the right to work in Norway without a work permit if he or she is employed by an EEA employer and if the following additional conditions are met:
• The assignment is of temporary nature.
• The assignee holds a work permit in the EEA country and has the right to return to that country.
For stays in Norway above three months, the assignee must apply for a residence card.
Exempt categories. The following foreign nationals are exempt from the work permit requirement for work travel lasting up to three months:
• Commercial travelers, business travelers or individuals who will attend meetings or seminars, receive training or attend precontract sales or negotiations.
• Research workers, lecturers and others invited to Norway by educational or research institutions for professional or charity reasons.
• Technical experts, technicians, consultants or instructors. The purpose must be to install, check, repair or maintain machines or technical equipment or to provide information on their use. The need for these workers may not exceed three months.
• Employees in private households or foreign nationals who are staying in Norway on visits.
• Professional athletes attending sports engagements in Norway.
• Civil servants who are paid by their own countries.
• Personnel of foreign rail, air, bus or truck services working internationally, and necessary watchmen and maintenance per sonnel on ships laid up in Norway.
• Journalists, foreign newspaper staff and radio or television teams on assignment in Norway, who are paid by foreign employers.
Self-employment. Non-EEA nationals who are self-employed and have established a business abroad may be granted a residence permit for a period of up to four years. Also, self-employed per sons who intend to engage in a permanent business activity are entitled to a residence permit if the presence of the self-employed person in Norway and active participation in running the business is necessary for the establishment or continued operation of the business.
H. Permanent residence
A permanent residence permit entitles the holder to permanently reside and work in Norway. This permit is granted, upon applica tion, to persons who have had permits for a total of three years that form the basis for a permanent residence permit in Norway.
I. Family and personal considerations
Family members. Family members of a foreign national who has a residence permit in Norway have certain privileges concerning the right to receive their own residence permits.
Close relatives of a person in Norway may receive residence permits, which are granted primarily to the spouse and to children younger than 18 years of age. In general, the person who is granted a residence permit for family reunification must be guar anteed sufficient economic support.
In general, an application for family reunification must be submitted from abroad, or via a family member or a third party with a power of attorney in Norway.
EEA nationals employed in Norway may normally be accompa nied by a spouse, children and parents. If the family member is an EEA national, he or she can also register through the registra tion scheme for EEA nationals. If not, he or she must apply for a residence permit.
A family immigration permit gives the right to work, regardless of whether job offers have been received.
Depending on nationality, different relation documents are required for family immigration. Relation documents, such as marriage contracts, divorce contracts and birth certificates, are officially required to have an apostille. However, this is not always enforced.
Driver’s permits. Foreign nationals may drive in Norway with their home countries’ driver’s licenses under the following circumstances:
• To drive a car with foreign license plates, the foreign driver’s license must be valid for at least one year.
• To drive a car with Norwegian license plates, the foreign driv er’s license must be valid for at least three months.
After the end of the allowed periods, a foreign license must be changed to a Norwegian driver’s license. A theoretical and a practical test may be required. The expatriate must apply for a Norwegian driver’s license at the Biltilsynet office in the county where he or she lives within one year of arriving in Norway. If an application for a driver’s license is made later than this time, it is difficult to obtain a driver’s license. In general, to obtain a driv er’s license in Norway, an individual must attend an authorized driving school and take both theoretical and practical lessons.
A driver’s permit issued by another EEA country is accepted on an equal basis with a Norwegian driver’s license.