Norway Tax Changes — Live Tracker

What changed

The Tilleggsskatteloven introduced the Income Inclusion Rule (IIR) and a Qualified Domestic Minimum Top-Up Tax (QDMTT) for fiscal years beginning on or after 1 January 2024. Groups with consolidated revenue of €750m or more in at least two of the previous four fiscal years must calculate their effective tax rate per jurisdiction under the GloBE rules and pay a top-up tax where the rate is below 15%. Norway's standard corporate tax rate is 22%, generally satisfying the minimum for ordinary activities, but incentives, exemptions, or offshore arrangements may create effective rate gaps.

Who it affects

• Multinational enterprise groups with €750m+ consolidated annual revenue
• Norwegian parent companies heading qualifying MNE groups
• Norwegian subsidiaries within foreign MNE groups where IIR or UTPR top-up applies

What to do

Confirm whether your group meets the €750m revenue threshold for two of the past four fiscal years. If so, perform a GloBE effective tax rate analysis per jurisdiction, identify any top-up liability, and prepare the required GloBE information return. Pay particular attention to Norwegian petroleum tax and tonnage tax regimes, which have specific interaction rules with the Tilleggsskatteloven. Engage a tax adviser experienced in Pillar Two compliance.

What changed

The differentiated zonal rates were adjusted for 2024: Zone 1 (general, most urban areas): 14.1%; Zone 1a (Oslo municipality): 14.1%; Zone 2: 10.6%; Zone 3: 6.4%; Zone 4: 5.1%; Zone 5 (most northern remote areas): 0%. The additional supplement (tilleggsavgift) of 5% on salary portions above NOK 850,000, which had been introduced in 2023, was removed from 1 January 2024. The eligible municipality map for each zone was also updated — verify your registered business location's zone.

Who it affects

• All Norwegian employers paying wages to employees
• Employers in northern or rural zones eligible for reduced rates
• Businesses with high-salary employees who were subject to the now-removed supplement

What to do

Verify which arbeidsgiveravgift zone your business address falls under using the updated municipality map on Skatteetaten.no, as zone boundaries are updated periodically. Update your payroll system to apply the correct 2024 zone rate and remove the high-salary supplement calculation for salaries above NOK 850,000. Confirm zone eligibility annually, particularly if you have multiple locations or if boundaries have changed.

What changed

Under the Aksjonærmodellen, dividends received by personal shareholders are grossed up by a factor of 1.72 and taxed at the ordinary income tax rate of 22%, resulting in an effective tax rate of approximately 37.84%. Shareholders are entitled to a skjerming (shielding deduction) equal to the acquisition cost of their shares multiplied by the annual skjermingsrente. For income year 2024, Skatteetaten set the skjermingsrente at 3.9%, meaning shareholders with a high cost base shelter more dividend income from tax compared to years with lower rates.

Who it affects

• Personal shareholders receiving dividends from Norwegian AS companies
• Founder-directors paying themselves dividends from their own AS
• Investors holding shares in Norwegian companies directly (not via funds)

What to do

Calculate your skjerming deduction for 2024 based on your shares' acquisition cost multiplied by the 3.9% skjermingsrente. Dividends received up to the skjerming amount are tax-free; excess dividends are taxed at 37.84% effective. Consider timing dividend distributions to maximise the skjerming deduction in years with higher skjermingsrente. Coordinate salary and dividend levels with your adviser to optimise total tax under the combined income tax, employer NI, and dividend tax rules.

What changed

Gains on the sale of a primary residence remain exempt from tax if the owner has lived in the property as their main home for at least 12 of the 24 months immediately before the sale date. This rule was tightened and clarified in recent years. Gains on holiday homes, investment properties, and secondary residences do not qualify for any exemption and are taxed as ordinary income at 22%. Losses on primary home sales are also not deductible if the exemption would have applied.

Who it affects

• Norwegian residents planning to sell their primary home
• Property investors and owners of holiday homes (fritidsbolig)
• Individuals who have lived abroad and are returning to sell a Norwegian property

What to do

Before selling a residential property, confirm whether you meet the 12-of-24-month primary residence requirement. If you have not yet met the threshold, consider delaying the sale until you qualify for the exemption. For holiday homes and investment properties, plan the disposal with full tax exposure in mind — model the 22% gain tax in your sale proceeds calculation. Seek advice if the property has been partly used as a primary home and partly rented.

What changed

A-meldingen is the monthly employer report covering salaries, benefits, and social contributions. From 2025, employers must report the employee's work location, including whether the employee is working from home, with the home address required for home office days. Additional granularity is required on employee benefits (particularly car benefits, phone, and broadband), and penalties for late, incomplete, or incorrect A-melding submissions have been increased. Payroll systems must be updated to capture and transmit the additional fields.

Who it affects

• All Norwegian employers with employees on payroll
• Businesses with employees working from home regularly or occasionally
• Payroll software providers and HR teams managing A-melding submissions

What to do

Update your payroll system to capture home office days and the employee's home address for A-melding reporting from 2025. Review your reporting of employee benefits (car, phone, broadband) to ensure the correct codes and values are being submitted. Set up monitoring to ensure A-meldingen is submitted by the 5th of each month following the payroll period to avoid the increased late-submission penalties. Contact your payroll software provider to confirm the 2025 A-melding specification changes are implemented.