Cessation of tax residence when moving from Norway (emigration)

Only if you take up permanent residency abroad can you be deemed to have moved from Norway for tax purposes. Temporary stays abroad do not cancel tax residence in Norway.

For your tax residence in Norway to cease when moving abroad, you must substantiate:

  • that you have taken up permanent residency abroad, 
  • that you have not stayed in Norway for one or more periods which exceed 61 days during the income year, 
  • that neither you nor your close relatives (spouse, cohabiting partner, child) have a place of residence available in Norway. 

If you have lived in Norway for less than ten years before the income year in which you take up permanent residency abroad, your tax residence in Norway will cease in the income year in which all three of these conditions are met.

If you have lived in Norway for a total of ten years or more before the income year in which you take up permanent residency abroad, your tax residence in Norway cannot cease until after the end of the third income year after the year in which you took up permanent residency abroad.

For your tax residence to cease, you must meet the following requirements in each of the three income years after you up permanent residence abroad:

  • your stay in Norway must not exceed 61 days, 
  • neither you nor your close relatives (spouse, cohabiting partner, child) have a place of residence available in Norway. 

Example

Per and Kari are both pensioners. They sold their home in Norway and moved to Spain in autumn 2013. They still have a cabin in Norway, which they have owned for 20 years. They are planning to stay in Norway for six weeks every summer and one week every Christmas. Per and Kari will be tax resident in Norway until 31 December 2016. If they stay in Norway for more than 61 days, they will continue to be tax resident in Norway after 2016.

These rules apply to everyone who has lived in Norway for one or more periods totalling more than ten years.

Please note that all whole or part  calendar days are included when calculating the period of stay in Norway.

The condition that you must not have a place of residence available in Norway means that neither you nor your spouse, cohabiting partner or minor children may own (either directly or indirectly), rent or be entitled on any other basis to use a home in Norway. Minor children living with a former spouse or cohabiting partner in Norway are not normally considered to have a place of residence available in Norway.

'Place of residence' means any housing unit which has been used as a dwelling. It also covers any housing unit with permanent water and wastewater systems all-year round, provided you are not prevented from using it as a dwelling by a land use plan or similar at the time you moved abroad.

You can still have a holiday home or other real property in Norway after you moved abroad without it preventing the cessation of your tax residence in Norway. This applies to housing units which do not qualify as a place of residence, i.e. housing units without permanent water and wastewater systems all-year round, and housing units which cannot be used as a dwelling at the time you moved abroad due to a land use plan or similar. It also applies to other housing units which were purchased at least five years before the year in which you moved abroad. It is a condition that neither you nor your spouse, cohabiting partner or children have used the housing unit as a dwelling during the five years before the year when you moved abroad.

You will always be tax resident in Norway in the year in which you move abroad and the three following income years if you have lived in Norway for ten years or more before the income year in which you take up permanent residency abroad. During this period, you must submit a tax return in Norway in the same way as if you lived here. You must substantiate that you did not have a place of residence available in Norway during this period and that you have not stayed here for more than 61 days in each year. The obligation to submit a Norwegian tax return will not lapse until the tax authorities in Norway have accepted that the tax residence in Norway has ceased.

Norway's right to levy tax may be limited by the provisions in the tax treaties which Norway has entered into with other countries.