Corporate Taxation Policies and Regulations in Norway

Certainly! Here’s an in-depth look at corporate taxation policies and regulations in Norway:

Corporate Taxation Policies and Regulations in Norway

Corporate Income Tax Rate

  • Flat Rate: The standard corporate tax rate in Norway is 22%. This applies to both resident and non-resident companies on income derived from Norwegian sources.

Tax Residency

  • Resident Companies: Companies incorporated in Norway or with effective management and control in Norway are considered resident and are taxed on their worldwide income.
  • Non-Resident Companies: These are taxed only on income sourced within Norway.

Taxable Income

  • Revenue: All forms of income, including business profits, interest, dividends, and capital gains, are subject to corporate tax.
  • Deductions: Companies can deduct ordinary business expenses, such as salaries, rent, and R&D costs, from their taxable income.

Group Taxation

  • Group Contributions: Norway allows for group contributions, which enable profit transfer between group companies to offset losses within the group, provided certain conditions are met.

Transfer Pricing

  • Arm’s Length Principle: Transactions between related parties must be conducted at arm’s length. Documentation requirements exist to ensure compliance.
  • Country-by-Country Reporting: Large multinational enterprises must provide detailed reports on their global allocation of income and taxes paid.

Thin Capitalization

  • Interest Deduction Limitation: Norway has rules restricting the deductibility of interest expenses on related-party debt to prevent profit shifting through excessive debt financing. The limit is generally 25% of taxable EBITDA.

Controlled Foreign Corporation (CFC) Rules

  • CFC Rules: These rules aim to prevent Norwegian companies from diverting income to low-tax jurisdictions. Passive income from controlled foreign entities may be taxed in Norway.

Value-Added Tax (VAT)

  • Standard Rate: 25%
  • Reduced Rates: 15% for food items and 12% for specific services.
  • Exemptions: Certain services, such as healthcare and education, are exempt from VAT.

Withholding Taxes

  • Dividends: A 25% withholding tax applies to dividends paid to foreign shareholders, which may be reduced under tax treaties.
  • Interest and Royalties: Generally, there is no withholding tax on interest and royalties paid to foreign entities.

Tax Incentives

  • R&D Incentives: Companies can benefit from tax credits and deductions for research and development activities.
  • Environmental Incentives: Tax benefits are available for investments in environmentally sustainable technologies and practices.

Compliance and Reporting

  • Tax Returns: Corporate tax returns must be filed annually, with the deadline typically set for the end of May.
  • Advance Tax Payments: Companies are required to make advance tax payments throughout the year based on estimated income.

Double Taxation Agreements (DTAs)

  • Tax Treaties: Norway has an extensive network of tax treaties with other countries to prevent double taxation and encourage cross-border trade and investment.

Anti-Avoidance Rules

  • General Anti-Avoidance Rule (GAAR): Norway has a GAAR to counteract tax avoidance schemes that lack commercial substance.
  • Specific Anti-Avoidance Rules: These target specific areas like transfer pricing and thin capitalization.


Norway’s corporate tax system is designed to be competitive while ensuring compliance and fairness. Understanding these policies and regulations can help businesses optimize their tax positions and ensure adherence to legal requirements. For detailed guidance tailored to specific circumstances, consulting with tax professionals or legal advisors is recommended.

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