What is Aksjonærmodellen (Shareholder Model)?
Norwegian system for taxing dividends and capital gains for personal shareholders of AS companies. Dividends and gains above a risk-free return (skjermingsfradrag) are grossed up by 1.72 and taxed at 22%, producing an effective rate of 37.84%. Dividends below the risk-free threshold are tax-free.
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Current Rate (Inntektsår 2025)
37.84% effective (on amounts above skjermingsfradrag); 0% on amounts below
Example
A shareholder has shares with a cost of NOK 100,000. Risk-free rate is 3.5%, giving skjermingsfradrag of NOK 3,500. The AS pays NOK 50,000 dividend. Taxable amount: (NOK 50,000 – NOK 3,500) × 1.72 = NOK 46,500 × 1.72 = NOK 79,980. Tax: NOK 79,980 × 22% = NOK 17,596.
How Aksjonærmodellen (Shareholder Model) works in Norway
The Aksjonærmodellen (shareholder model) is the Norwegian framework for taxing dividends and capital gains earned by personal shareholders (privatpersoner) on shares in Norwegian AS and ASA companies.
**The purpose of the model**
The Aksjonærmodellen was introduced in 2006 as part of a major tax reform. Its goal was to create neutrality between retaining earnings in a company versus distributing them: a shareholder should not be better or worse off by virtue of timing alone. The model achieves this by providing a risk-free deduction (skjermingsfradrag) equal to a notional return on the investment, and taxing only the return above that threshold.
**Skjermingsfradrag calculation**
The skjermingsfradrag (risk-free deduction or shield deduction) is calculated as: Skjermingsfradrag = Skjermingsgrunnlag × Skjermingsrente
- **Skjermingsgrunnlag**: the acquisition cost of the shares plus any capital contributions + any unused skjermingsfradrag carried forward from prior years (unused deductions accumulate and can be used against future dividends or gains) - **Skjermingsrente**: set by Skatteetaten annually, based on the risk-free interest rate (3-month Treasury bill rate, approximately 3–4% in recent years). Published in January after the income year.
The skjermingsfradrag is calculated per share and is assigned to the shareholder, not the company. The AS company computes the tax value per share for its RF-1167 filing; the shareholder computes their individual skjermingsfradrag.
**Taxing dividends above the threshold**
Dividends above the skjermingsfradrag are 'grossed up' by a factor of 1.72 before inclusion in alminnelig inntekt. The factor reflects the effective total tax burden: - The company paid 22% corporate tax, leaving 78 øre per krone earned - To get back to the pre-corporate-tax equivalent, multiply by 1/0.78 ≈ 1.282 - Then apply 22% ordinary income tax on the grossed amount: 1.282 × 22% ≈ 28.2% on the gross - On the after-corporate-tax amount, the effective personal rate is: 1.72 × 22% = 37.84%
**Capital gains under the Aksjonærmodellen**
When a personal shareholder sells shares in an AS, capital gains are computed as: sales proceeds minus acquisition cost minus accumulated unused skjermingsfradrag. The net gain is grossed up by 1.72 and taxed at 22%: the same rate as dividends. Unused skjermingsfradrag at the point of sale reduces the taxable gain.
**FIFO and portfolio tracking**
When a shareholder holds multiple tranches of the same share purchased at different times and prices, FIFO (first in, first out) applies for determining which shares are sold. Skatteetaten's Aksjonærregisteret pre-populates shareholder returns with this information based on RF-1167 filings from each company.
Related terms
Dividend paid from a Norwegian AS. When paid to a personal shareholder: taxed at effective 37.84% rate (dividend × 1.72 × 22%) above the skjermingsfradrag. When paid between Norwegian/EEA AS companies: 97% exempt under Fritaksmetoden. Dividends can only be paid from distributable equity.
Norwegian participation exemption. Dividends and capital gains between qualifying Norwegian and EEA companies are 97% exempt from tax (3% included at 22% = effective 0.66% tax). Prevents cascade taxation in corporate groups. Does not apply to non-EEA companies in low-tax jurisdictions.
Norwegian private limited company. The most common business structure for active trading. Minimum share capital NOK 30,000. Registered with Brønnøysundregistrene (BRREG). Shareholders have limited liability: personal assets are protected.
Norwegian personal income tax system. Flat 22% ordinary income tax on net income, plus trinnskatt (bracket tax) on gross income up to 17.6%, plus 7.9% trygdeavgift (national insurance) on earned income. Total marginal rate on highest earners can exceed 47%.
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