Tax liability - foreign limited companies

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 are subject to the ordinary tax liability in Norway.

A company or similar which is established under Norwegian company law, is usually 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.

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.

Tax treaties

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