NORWAY Law and Practice Contributed by: Sicilie Tveøy, Lars Christensen, Ramborg Elvebakk and Karen Margrethe Bugge, Advokatfirmaet Hjort AS
2.2 International Planning As Norwegian families and businesses become more international, cross-border issues increasingly impact succession planning. It is common for high net worth Norwegian families to have assets abroad (eg, vaca - tion real estate, foreign bank accounts, cars) and some have family members living in different jurisdictions. This can create conflicts of law (different inheritance rules in different countries) and tax exposure in multi - ple jurisdictions. Norwegian succession plans include planning in all countries where the family has proper - ties, resides, or has strong connections through family members, studies, or other ties as in-laws. The main rule is to include foreign wills or estate plans in the Norwegian planning to cover assets in other countries, ensuring local formalities are met and considering tax implications in countries where family members live or have strong connections. This also includes considering different inheritance laws in case other countries have more favourable laws for the specific family. Advisers must ensure that succession plans are synchronised across jurisdic - tions, which may involve obtaining professional advice in each country to harmonise the plan. In summary, internationalisation brings complexity – multiple legal systems and tax regimes interact, requiring careful planning so that wealth can pass smoothly to fam - ily across borders without unintended tax burdens or legal disputes. 2.3 Forced Heirship Laws Norway has forced heirship rules (legally termed “compulsory inheritance” for children). Under the Nor - wegian Inheritance Act, two thirds of the net estate is reserved for linear heirs (children and their descend - ants). However, each child’s compulsory share is capped at a fixed amount: currently 15 times the Norwegian National Insurance basic amount (15G), which is about NOK1.8 million per child as of 2025. If the statutory two thirds would give a child more than this cap, the excess can be freely distributed by writing a will. Forced compulsory inheritance ensures that children cannot be disinherited beyond that limit. The surviving spouse has also a strong inheritance right to one quarter of the estate, but this can also be
Norway maintains a public beneficial ownership reg - ister (the “Register of Beneficial Owners”), requiring companies and certain legal entities to disclose their ultimate beneficial owners. This register enhances corporate transparency by making ownership infor - mation publicly accessible, thereby supporting anti- money laundering measures and tax compliance. Norway has general anti-avoidance rules in its tax leg - islation to target perceived abuses. In 2020, a general anti-avoidance principle was codified to allow the dis - regarding of arrangements with no primary purpose other than tax avoidance. 2. Succession 2.1 Cultural Considerations in Succession Planning Norwegian succession planning is shaped by small family structures, few wealthy families, and strong traditions of equality, gender equality and transpar - ency. Norwegian families are typically small, with few children, and there is a strong cultural norm of treat - ing children equally in inheritance. The Inheritance Act reflects this equality by enforcing forced heirship (chil - dren have fixed inheritance rights), which means that most families do not have large estates to bequeath freely, while wealthy families have more extensive tes - tamentary freedom. When family assets are concentrated in a business, it is common in Norway for one child to take over the business, while the other children receive more liquid or accessible assets. The older generation typically transfers ownership gradually, often retaining control of the company until their passing. In Norway, families often seek to avoid conflict and prioritise amicable solutions when distributing assets upon death. Among those who own multiple proper - ties, it is common to own vacation homes or family cabins, many of which have been inherited through generations. There is a strong tradition of keeping such properties within the family to preserve heritage and maintain places for family gatherings.
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