Shielding deduction
The shielding basis is calculated per share and accumulates when unused. We reconstruct it from the year of acquisition — in older holdings this alone often shelters a full year of dividends.
Salary is deductible for the company but attracts employer's contributions and progressive bracket tax. Dividend is not deductible, and carries an effective charge of 37.84 % once the 22 % corporate layer is included. Neither is automatically better.
The right split depends on your pension accrual, your sickness and parental benefit entitlement, your loan applications, your wealth-tax exposure and the size of your unused shielding deduction. We model all of it over a five-year horizon, then give you a number for this year and a policy for the next four.
The shielding basis is calculated per share and accumulates when unused. We reconstruct it from the year of acquisition — in older holdings this alone often shelters a full year of dividends.
Unlisted shares, working capital and commercial property are all valued under specific rules with statutory discounts. Applying the correct basis is legitimate, and the difference is substantial.
Letting, holiday homes, the primary residence exemption and the one- and two-year holding rules for tax-free sale. Timing a sale by a few months frequently changes the outcome entirely.
The share savings account (ASK), holding shares personally or through a company, and the timing of realised gains against realised losses within the income year.
Norway has no inheritance tax, but the continuity principle carries the parent's tax positions to the next generation. Handing over a company badly can create a liability that never existed before.
A sale routed through a holding company is treated very differently to a personal sale. That structure has to exist well before the buyer appears, not during negotiations.
Both take NOK 1 200 000 out of a company with NOK 3 million in profit. One takes it entirely as salary; the other follows a modelled split with the shielding deduction applied.
| Position | Owner A — salary only | Owner B — modelled split |
|---|---|---|
| Salary drawn | NOK 1 200 000 | NOK 780 000 |
| Dividend drawn | NOK 0 | NOK 420 000 |
| Employer's contribution | NOK 169 200 | NOK 109 980 |
| Shielding deduction applied | NOK 0 | NOK 96 000 |
| Combined tax & contributions | ≈ NOK 612 000 | ≈ NOK 528 000 |
| Difference | — | ≈ NOK 84 000 per year |
Simplified illustration for the 2025 income year, ignoring municipal variation and personal deductions. Not advice — the correct split for you depends on facts we would need to see.
“I had drawn the same salary for eleven years because that is what my accountant set up in 2013. Nobody had ever recalculated it. The revision paid for itself in the first quarter.”
If the answer is “when the company was set up”, the tax check will take three minutes and is likely to be the most valuable three minutes of your quarter.