NORWAY Trends and Developments Contributed by: Bernhard Getz-Jeffreys and Johannes Wiegaard, Ro Sommernes Advokatfirma AS
There are several cases ongoing and pending for the courts relating to individuals’ acquisition of shares in companies with high values of fully paid-in capital where the tax authorities claim that the tax position was the main attraction for the acquisition and as such should be revoked. Another intention of the proposed amendments is to avoid similar cases in the future, as the amount fully paid-in on each share will be reduced to the acquirer’s purchase price for each share. 2.4 Transition from petroleum revenues Norway’s dependence on petroleum revenues remains a critical long-term challenge. The oil and gas indus - try contributed NOK336 billion to the state budget in 2025, representing approximately 16% of the state’s revenues from taxes and duties. As the global ener - gy transition accelerates and petroleum production inevitably declines, Norway must develop alternative revenue sources and economic sectors. The expansion of resource rent taxation to aquaculture and wind power represents one approach to diversi - fying the tax base beyond petroleum. In recent years, resource rent taxes have been introduced for aquacul - ture and land-based wind power, with a formal rate of 32.1% in 2026, in addition to ordinary corporate tax. These resource rent taxes are designed as largely neutral cash flow taxes with immediate deduction for invest - ments, ensuring that projects that were profitable before the resource rent tax remain profitable afterwards. Industry lobbies initially raised significant concerns about these resource rent taxes, warning of job losses, layoffs and operational cutbacks. Although protests have since subsided considerably and the industry appears to have largely accepted the cur - rent taxation framework, the government recently abandoned a proposal to extend resource rent tax to smaller hydropower plants following substantial industry criticism – demonstrating that the regulatory landscape remains in flux. 3. Looking forward: the path to a comprehensive tax reform The government has signalled its intention to pursue comprehensive tax reform through a white paper to be presented in 2027, with the purpose of establishing agreement on important elements of the tax system
across political dividing lines. To obtain input for this work and lay the groundwork for a broad compro - mise, the government is seeking to initiate a broadly anchored tax commission. The reform process recognises that taxation of busi - nesses and owners will be central to the reform work, while larger changes to the tax system must be viewed holistically to ensure logical coherence and proper balancing of considerations including efficiency, dis - tribution, predictability, simplicity, robust tax bases and competitiveness. The background for this comprehensive reform effort lies partly in the intense political debate about taxa - tion that preceded the September 2025 parliamentary election. Wealth taxation, in particular, emerged as a significant electoral issue, with different parties propos - ing markedly different approaches. The centre-left gov - ernment faced criticism from opposition parties about the impact of wealth tax increases on entrepreneurship and capital flight, while defending the tax as essential for maintaining equity and funding welfare services. The political disagreements highlight the fundamental tension in Norwegian tax policy between maintain - ing a robust welfare state and ensuring competitive conditions for business. These divergent views make cross-political consensus challenging but also under - score why a durable tax settlement spanning multiple electoral cycles would provide valuable stability for businesses and investors that suffer from the constant changes in the tax framework dependent on the views of the regime at any particular time. In this debate, all parties recognise that Norway’s tax system faces multiple simultaneous pressures – demo - graphic ageing, climate obligations, digital transforma - tion, petroleum transition and international tax compe - tition – that cannot be addressed through piecemeal annual adjustments alone. A comprehensive, politically durable reform framework will be essential for main- taining the fiscal capacity to support Norway’s welfare state while fostering economic dynamism and com - petitiveness and balancing the income and tax burden across different segments of society.
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