What is the corporate tax rate in Norway?
Norway's corporate income tax (selskapsskatt) is 22% flat on all taxable profits of AS companies. Financial companies pay 25%. When profits are distributed as dividends to personal shareholders, the combined effective rate rises to approximately 51.5% due to the Aksjonærmodellen's 37.84% tax on dividends.
Detailed Explanation
Norway's corporate income tax, known as selskapsskatt, is levied at a flat 22% rate on the taxable profits (alminnelig inntekt) of Norwegian AS (Aksjeselskap) and ASA (Allmennaksjeselskap) companies. This flat rate applies with no graduated brackets and no regional variation — every krone of taxable profit in a standard Norwegian company faces the same 22% rate.
The financial sector surcharge
Financial companies — banks, insurance companies, and other regulated financial institutions — pay 25% corporate tax rather than the standard 22%. This 3-percentage-point surcharge was introduced because most financial services are exempt from MVA (Norwegian VAT), meaning the financial sector does not contribute to public finances through consumption taxes in the same way as other industries.
Taxable income calculation
Corporate tax is levied on alminnelig inntekt — taxable income that starts with accounting profit and adjusts for Norwegian tax law differences:
- Depreciation: accounting depreciation is replaced by saldoavskrivning (declining balance depreciation) at prescribed statutory rates. Different asset groups (saldogrupper A–J) have different rates, ranging from 2% for buildings to 30% for electronic data processing equipment.
- Dividends from Norwegian and EEA AS companies: 97% exempt under Fritaksmetoden (see below). Only 3% is taxable at 22%, producing an effective rate of 0.66%.
- Capital gains on shares in qualifying companies: 100% exempt under Fritaksmetoden.
- Interest deduction limitations (rentebegrensning): net related-party interest expense exceeding 25% of EBITDA is non-deductible in the year incurred (but can be carried forward for 10 years).
- Tax losses: carried forward indefinitely with no time limit.
Fritaksmetoden — the participation exemption
Fritaksmetoden is Norway's participation exemption system that prevents cascade taxation in corporate groups. When a Norwegian AS receives a dividend from another Norwegian or EEA AS, 97% of the dividend is exempt from corporate tax. Only 3% is included in taxable income and taxed at 22%, producing an effective tax rate of just 0.66% on inter-company dividends.
Capital gains on selling shares in qualifying companies (Norwegian or EEA AS companies not in low-tax jurisdictions) are fully 100% exempt under Fritaksmetoden — no 3% rule applies to gains.
This makes the Norwegian holding company (holdingselskap) structure highly tax-efficient: profits can be accumulated in an AS at 22% and dividends can pass between group companies at 0.66% effective tax.
Tax on dividends to personal shareholders
When AS profits are distributed to personal shareholders, Norway's Aksjonærmodellen applies. Dividends above a risk-free return threshold (skjermingsfradrag) are grossed up by a factor of 1.72 and taxed at 22%, producing an effective personal tax rate of 37.84%.
The combined tax burden on corporate profits distributed to a personal shareholder is: - Company pays 22% selskapsskatt on NOK 100 profit → NOK 78 after-tax - Personal shareholder receives NOK 78 dividend (above skjermingsfradrag) - Personal tax: NOK 78 × 1.72 × 22% = NOK 29.52 - Total tax: NOK 22 + NOK 29.52 = NOK 51.52 out of NOK 100 → combined effective rate 51.5%
This high combined rate is why many Norwegian AS owners structure their affairs to accumulate retained earnings in a holding company (where dividends move tax-efficiently at 0.66%) and only take personal dividends as needed.
SkatteFUNN R&D tax credit
Norway's SkatteFUNN scheme provides a 19% direct tax credit on qualifying R&D costs, up to NOK 25m per year for SMEs (large companies: NOK 50m). This credit directly reduces the 22% selskapsskatt liability — and if the credit exceeds the tax liability, it is refunded in cash. This makes SkatteFUNN an extremely valuable tool for technology and product companies.
When tax is paid
AS companies pay advance corporate tax (forhåndsskatt) in two instalments — 15 February and 15 April of the following year — based on an estimate. Final assessment comes in October/November; balance due within 3 weeks of assessment.
Source: https://www.skatteetaten.no/bedrift-og-organisasjon/skatt/skattesatser/skatt-pa-selskap-og-naringsvirksomhet/
Real-World Examples
Small tech AS with NOK 1m profit
Teknologi AS earns NOK 1,000,000 taxable profit. Corporate tax: 22% = NOK 220,000. After-tax retained earnings: NOK 780,000. If distributed immediately as a dividend to the founder: personal tax (Aksjonærmodellen, above skjermingsfradrag) = NOK 780,000 × 1.72 × 22% = NOK 295,128. Total tax on NOK 1m: NOK 515,128 (51.5%).
Holding company deferral strategy
Trading AS pays NOK 780,000 dividend to Holding AS (after paying 22% corporate tax). Fritaksmetoden: only 3% taxable at 22% = NOK 5,148 tax. Holding AS retains NOK 774,852. The founder defers personal dividend tax until actually needed, allowing continued investment and compounding at a near-zero inter-company tax rate.
Financial company at 25%
A small fintech firm classified as a financial company pays NOK 250,000 on NOK 1m profit (25% rate). The 3-percentage-point difference from a standard AS costs NOK 30,000 extra tax per year. Classification as a financial company is determined by the nature of activities, not merely by holding financial assets.
Common Mistakes to Avoid
- Assuming Norway's corporate rate is higher than 22% because personal tax rates are high — the corporate rate itself is competitive by European standards.
- Ignoring Fritaksmetoden when structuring a corporate group and paying full corporate tax on inter-company dividends.
- Not applying for SkatteFUNN for software or product development work — the 19% tax credit is refundable even in loss-making years.
- Confusing the 22% corporate rate with the effective combined rate of 51.5% when dividends are paid to personal shareholders — these are different concepts.
Frequently Asked Questions
Does Norway have a small company tax rate?
No. Norway has a single flat 22% corporate rate (25% for financial companies) with no reduced rate for small companies. However, small companies can benefit from simplified accounting rules, and SkatteFUNN provides a 19% R&D tax credit refundable even in loss years.
How does Norway's corporate rate compare to the UK and EU?
Norway's 22% rate is competitive: below Germany (approximately 30% combined federal + municipal), France (25%), the Netherlands (25.8%), and the UK (25% for profits over £250,000). It is higher than Ireland (12.5%) and Hungary (9%).
Can a Norwegian company carry forward tax losses?
Yes, tax losses carry forward indefinitely with no time limit in Norway. There is no cap on the amount carried forward. Losses can be used to offset future taxable profits in full.
Is there a separate municipal or county corporate tax in Norway?
No. Unlike Germany (Gewerbesteuer) or some US states, Norway has a single unified corporate tax rate. There is no separate municipal or regional corporate tax. The 22% (or 25% for financials) is the total rate.
When does the AS pay its corporate tax?
Corporate tax for an income year is paid as advance tax (forhåndsskatt) in two instalments — 15 February and 15 April of the year following the income year. Final assessment typically arrives October/November; any balance is due within 3 weeks.
Practical Tips
- Model both the 22% corporate rate AND the Aksjonærmodellen personal rate when planning dividend timing — deferring dividends inside a holding company saves significant personal tax.
- Apply for SkatteFUNN before starting R&D work — pre-approval from Norges Forskningsråd gives certainty on what qualifies.
- When forming a group structure, always use a holding AS (holdingselskap) above the operating AS to take advantage of Fritaksmetoden.
- Review the rentebegrensningsregler if your AS has related-party loans — excessive inter-company interest can be disallowed.
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