Companies and businesses that are resident in a country with which Norway has  a tax treaty won't normally be liable to pay tax to Norway on this income, unless the hire business is conducted through a permanent establishment in Norway.

‘Hiring-out of labour’ means that the lessor provides personnel available to work for another party’s enterprise, and that the lessor is not responsible for the outcome of the work performed by the personnel.

The Norwegian Tax Administration decides whether a contract given to a foreign contractor constitutes the hiring-out of labour.

Criteria for the hiring-out of labour  

The following circumstances suggest that labour is being hired out:

• The client is responsible for managing the work.
• The client is responsible for or bears the risks relating to the results of the work.
• The client has the use of and is responsible for the workplace where the work is carried out.
• An hourly rate or time-based price has been set.
• The client's materials and tools are used during the performance of the assignment.
• The lessor does not unilaterally determine the number of employees or their qualifications.