Ordinary tax liability in Norway means that you're liable to pay tax to Norway on all your wealth and income both in Norway and abroad.
Companies and other businesses that are domiciled in Norway and persons who're resident in Norway are subject to the ordinary tax liability in Norway.
A company or similar which is established under Norwegian company law, is always resident in Norway. A company established in another country can also be resident in Norway if the company's real management is in Norway. This is usually determined by where board meetings are held and where the management of day-to-day operations takes place, but other circumstances concerning where the company's real management happens may also be taken into account.
A person will be deemed to be resident in Norway if he or she resides in Norway for more than 183 days over a twelve-month period. The same applies to anyone who resides in Norway for more than 270 days over a thirty six-month period. The person will be deemed to be resident from 1 January in the income year in which the period of residence which exceeds the number of days referred to above falls. If the 183 days over a twelve-month period fall within a calendar year, the person will be deemed to be resident from the first day of residence.
Limited tax liability
Companies and other businesses that are not domiciled in Norway and self-employed persons who are not resident in Norway may become liable for tax in Norway on income generated through activity that they carry on or participate in and which is operated or managed from Norway. They may also become liable to pay tax for the hiring of labour to Norway.
Special rules concerning the continental shelf
In accordance with the Petroleum Tax Act, liability to pay tax in Norway arises with regard to income from exploration for and extraction of subsea petroleum deposits in Norwegian territorial waters and on the continental shelf. This also applies to associated activity and work.
The above description applies to tax liability under Norwegian law. Norway has entered into tax treaties with many countries. If a company or business is resident in a country with which Norway has entered into a tax treaty, Norway may have entirely or partially waived its entitlement to tax the income. See the tax treaties between Norway and other countries at regjeringen.no
If a company or business is resident in a country with which Norway has entered into a tax treaty, the condition for there being tax liability in Norway as regards the business income is that the income was earned through activity which is carried out through a permanent establishment in Norway. More information on permanent establishment
In the case of hiring-out of labour to Norway, the company and the business will not normally be deemed to have a permanent operating base in Norway under the tax treaties, unless the hire activity is carried out through a permanent establishment in Norway. More information on hiring-out of labour