Treaty analysis
Norwegian residents are taxable on worldwide income. Non-residents are taxable only on Norwegian-source income. Between those two statements sit the cases that actually cause trouble: the founder who moved to Portugal but kept a flat in Oslo; the Swedish group whose project manager has effectively been operating from Norway for fourteen months; the family that emigrated with unrealised share gains.
Each of these has a defined answer in Norwegian domestic law read together with the relevant treaty. The cost of guessing is double taxation on one side, or a reassessment with interest and penalty on the other.
A foreign company can create a taxable presence in Norway without ever registering a company here — through a fixed place of business, a construction site exceeding the treaty threshold, or an agent who habitually concludes contracts. We assess the exposure before it crystallises, and where a PE already exists, we register and file it properly rather than waiting to be found.
Relief comes either by credit or by exemption depending on the treaty and the income type. Claiming the wrong method — or failing to document foreign tax actually paid — is the most common reason a legitimate relief claim is refused. We prepare the claim with the evidence attached.
Intra-group pricing must be at arm's length, and groups above the statutory thresholds must hold documentation ready for submission on request. We prepare local files, benchmark intra-group services and interest, and defend the method chosen if it is questioned.
Leaving Norway triggers a deemed realisation of latent gains on shares above the threshold. The liability can be deferred, but the deferral must be claimed and secured correctly, and the rules have tightened materially in recent years. Timing the move is the whole exercise.
Individuals moving to Norway need their entry position set: the opening value of assets, the treatment of foreign pensions and property, and whether the PAYE scheme for foreign workers is advantageous in the first years.
Branch (NUF) or subsidiary AS, VAT representation, employer registration, a-melding obligations and the practical question of how profits will eventually be repatriated. Decided once, at the start, rather than corrected in year three.
| Payment | Domestic rate | Typical treaty position |
|---|---|---|
| Dividends to non-resident individuals | 25 % | Commonly reduced to 15 % or lower |
| Dividends to EEA corporate shareholders | 25 % | Often 0 % where the exemption method conditions are met |
| Interest to related parties in low-tax jurisdictions | 15 % | Reduced or eliminated under many treaties |
| Royalties to related parties in low-tax jurisdictions | 15 % | Reduced or eliminated under many treaties |
General guidance only. The applicable rate depends on the specific treaty, beneficial ownership and whether the recipient is genuinely established in the treaty state.
Tell us where the activity, the people and the money are, and we will tell you where the tax falls — before the second jurisdiction does it for you.