NORWAY Law and Practice Contributed by: Sicilie Tveøy, Lars Christensen, Ramborg Elvebakk and Karen Margrethe Bugge, Advokatfirmaet Hjort AS
and deferring tax until the value is withdrawn privately. To keep the shares in the company, individuals tend to restructure to gain a holding company with fam - ily owners or share companies and thereafter share equally between heirs, without paying any realisation tax. Values may be transferred tax-free between spouses, which can be used to reduce the tax burden by fully utilising both spouses’ basic deductions. However, transferring to either spouse has disadvantages, and it is seldom used in Norway. In addition, Norway has certain tax-preferred savings opportunities in pension products and special savings accounts. These instruments are intended for long- term savings. 1.4 Taxation of Real Estate Owned by Non- Residents Norway taxes real estate located in Norway regardless of the owner’s residence or citizenship. Rental income from Norwegian property earned by non-residents is subject to Norwegian income tax. Capital gains on the sale of Norwegian real estate by a non-resident owner are also taxable in Norway. However, if a non-resident individual owner meets the same conditions as residents for tax-free sale (eg, selling a primary residence after sufficient occupancy period), that exemption applies equally. Norway does not impose withholding tax on property sale gains, but the seller must report and pay any applicable tax. Non-residents are generally not subject to Norway’s net wealth tax, meaning ownership of Norwegian property by a foreign resident does not trigger wealth tax. The municipal property tax (0.1%–0.4%) applies to the property itself, regardless of ownership. Upon purchasing real estate, the buyer pays a docu - ment fee to the state of 2.5% of the property’s value. 1.5 Stability of Tax Laws Generally, Norway’s tax laws have remained relatively stable, with gradual adjustments rather than major overhauls. However, high net worth individuals con - tinue to keep a close watch on specific areas where
changes are emerging. The repeal of the inheritance and gift tax in 2014 marked a significant one-time change in Norway’s tax regime. This was subse - quently followed by the introduction of the continuity principle, which has remained in place since. In recent years, the primary developments in Norwe - gian tax policy have centred on adjustments to rate and valuation rules. For example, during 2022–23, the upper rate of the net wealth tax was increased to 1.1% for wealth exceeding approximately NOK20 million. At the same time, valuation discounts for shares and secondary homes were reduced. These measures reflect a clear policy shift towards increasing the tax burden on high net worth individuals. As a result, there has been a noticeable trend of wealthy individuals relocating abroad, particularly to Switzerland. This movement suggests that concerns about future tax increases or the possible reintroduc - tion of estate tax are influencing decisions among this group. As of 2025, notable changes include a new Exit Tax for those emigrating (imposing tax on latent gains in shareholdings) – making the situation even worse for many individuals. 1.6 Transparency and Increased Global Reporting Norway is an active participant in international tax transparency initiatives and has taken steps to close loopholes. Norway has implemented the OECD Com - mon Reporting Standard (CRS), requiring Norwegian financial institutions to report foreign account hold - ers to their home countries, while Norway receives information on offshore accounts held by Norwegian taxpayers. Norway has an intergovernmental agreement with the US to implement FATCA, requiring Norwegian banks to disclose accounts held by US persons. Although Norway is not an EU member, it voluntarily aligns with many EU standards. For example, Nor - way has implemented national rules similar to the EU’s DAC6, requiring the mandatory disclosure of aggres - sive cross-border tax arrangements.
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