Loans to personal shareholders

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Since 7 October 2015, loans (credit and/or the provision of security) from private limited liability companies, etc. to personal shareholders and their associates have been taxed as a dividend for the recipient according to the shareholder model.

The part of the loan which, when combined with any ordinary dividends, exceeds the deduction for risk-free return, must be adjusted upwards by a factor of 1.16 for the 2016 income year and taxed as general income. The upward adjustment takes place in connection with the tax calculation.

The repayment of loans which have previously been subject to dividend taxation is treated as the deposit of new capital by the shareholder.

See examples of how loans to shareholders should be completed and reported in the Shareholder register statement.


Loans which are taxed as a dividend must be multiplied (adjusted upwards) by a factor of 1.15 before taxation.

In practice, this means that the effective tax rate is 28.75 per cent.

Example 1:

You receive a dividend of NOK 100,000. This amount must be multiplied by 1.15 before taxation of 25 per cent.

100,000 x 1.15 = 115,000

115,000 x 0.25 = 28,750

In this example, the tax on your dividend of NOK 100,000 is NOK 28,750.

The example only shows upwards adjustment and does not take into account any deduction for risk-free return.

The upward adjustment of taxable dividends takes place automatically in the Norwegian Tax Administration's systems and is shown in the tax return.

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