Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, it can not replace a tax advice, or be considered as an official information.
Yes we tax in Norway
New tax reform: No specific information
New tax treaties:
- Tax treaty between Norway and Zambia is ratified by Zambia. .
- Tax treaty between Norway and Slovak Republic is under negotiation.
- Protocol to tax treaty between Norway and Switzerland under negotiation.
- Protocol to tax treaty between Norway and Thailand under negotiation.
Local tax advisors
No specific information on the local tax advisors.
Local tax administration
There is no definition of Permanent Establishment under the domestic tax law.
Resident companies are taxed on their worldwide income.
There is no definition of Residence under the domestic tax law, however entities are considered to be resident for tax purposes in Norway if their place of management & control is in Norway.
Note: the concept of permanent establishment and place of residence are subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 24%.
Small companies (profits less than around 1.6mEUR) are taxed under a 16% CIT tax rate.
Non-taxable income includes the following:
- Income from real property located abroad.
- Dividends received from qualifying participations? … No specific information
- Certain capital gains deriving from qualifying participations? … No specific information
- Profits from a permanent establishment abroad? … No specific information
Non-deductible expenses includes the following:
- Dividends benefiting from the participation exemption ;
- Payment exceeding the arm’s length principle;
- CIT and similar taxes on income
Carry forward: Yes indefinitely, but some restrictions may apply.
Carry back: Yes 2 years.
Companies should submit the tax return annually before the end of May of the following year.
Annual tax returns are established by the company on a self-assessment system.
No advance payments are required.
Whithholding Taxes (payment to foreign companies)
The local tax rates in Norway are the following, subject to the provisions of an applicable double tax treaty, if any.
There is no WHT on the profits paid from a branch to its foreign head office.
The general rate of WHT on dividends is 25% of the gross amount.
The general rate of WHT on interest is 0%.
The general rate of WHT on Royalties is 0%.
The general rate of WHT on management fees is 0%.
The general rate of WHT on technical services is 0%.
Capital gains are taxed as general income under the regular CIT.
Note: certain capital gains are exempt.
Standard VAT tax rate is 25%
Reduced tax rates are:
- 15% (among others, foodstuffs);
- 10% (among others, passenger transport, hotel, cinemas, …)
Zero-rated supplies include, subject to certain conditions:
- exports of goods and services;
- Vessels or Aircraft engaged in commercial international traffic;
- Services related to zero-rated vessels and Aircraft;
- Transport of goods and services directly related to import and export of goods;
- Local passenger transportation.
Exempt supplies include, subject to certain conditions:
- Certain financial services;
- Health services;
- Supply or lease or real property;
- Training and education;
Note: exempt transactions differ from zero-rated transactions in that the input VAT associated with exempt transactions is not deductible.
In case where for a tax period, Input VAT exceeds Output VAT, certain non-resident companies may apply for a refund provided that they register in Norway for VAT purposes.
Refunds are subject to the reciprocity principle, which means that Norway only refunds VAT to foreign companies in countries that offer similar refunds to Norway companies.
No other specific information of VAT in Norway.
The general statute of limitation is 5 years starting at the end of the year in which the tax return had to be filed.
The statute of limitation could be extended to 10 years in certain extraordinary cases.
There is no foreign exchange control in Norway. Income and capital could be freely repatriated.
There are no thin capitalization rules in Norway. However, interest exceeding the arm’s length principle are not deductible.
Do not hesitate to share your experience in Norway with us in the comments below. Any comments are welcome !