Resource rent tax on onshore wind power

From the 2024 income year, owners of wind power plants with more than five wind turbines, or with a total maximum installed capacity of 1 MW or more according to their licence, must pay resource rent tax to the state.

The rules on resource rent tax for onshore wind power entered into force on 1 January 2024.

The resource rent tax is calculated based on the assessed resource rent income at the wind power plant. The resource rent tax comes in addition to tax on ordinary income.

The wind power industry has exclusive access to valuable land for commercial activity that can generate extraordinary returns. The purpose of resource rent taxation is to ensure that society receives a larger share of this return.

Who does it apply to?

The rules on resource rent tax apply to owners of onshore wind power plants in Norway. The person or entity that owns the wind power plant, or a share of it, is liable to resource rent tax.

In this context, the owner is the person or entity that holds the essential ownership rights, for example:

  • the right to sell the plant or to prevent its sale
  • the right to pledge it as security
  • the right to take part in further development
  • the right to determine production volume and production periods
  • the obligation to cover investment and operating costs

Tax calculation unit

The wind power plant is the calculation unit for the resource rent tax. The resource rent income is assessed separately for each wind power plant. If the business owns several wind power plants, it must report resource rent income for each plant. Each wind power plant has a power plant ID (kraftverkID), which you can find in NVE’s database of developed wind power plants. This number must be reported as the "serial number" in the tax return.

Resource rent tax applies to wind power plants that have more than five wind turbines or a total maximum installed capacity of 1 MW or more according to their licence.

When assessing whether the threshold for resource rent tax liability is met, it’s decisive whether the generators or wind turbines form part of the same wind power plant.

A wind power plant can consist of one or more wind turbines and the associated electrical equipment for production, such as:

  • internal electrical systems (cables or overhead lines)
  • internal transformer installations and production lines
  • other structural constructions
  • control and monitoring facilities

To determine what counts as one wind power plant, you should consider whether the relevant areas naturally form a single planning area, and whether there will be shared infrastructure, roads, and grid connections. Ownership may also be relevant, but it’s not decisive.

What the enterprise must do

Enterprises subject to resource rent tax must determine the resource rent income in the tax return and the business information. You must report the resource rent income even if it’s negative.

Calculating the resource rent income

You calculate resource rent income by determining gross resource rent income and subtracting the costs.

+

Sum of spot market prices multiplied by the plant’s actual production in the relevant time periods.

There are exceptions for certain types of contracts, where the production volume in the contract must be valued at the contract price or the hedged price. You’ll find information about these exceptions further down the page.
+ Gain on divestment of fixed assets used for wind power production
+ Subsidies for the production of new wind power
+ Income from issued electricity certificates
+ Income from issued Guarantees of Origin (GO)
= Gross resource rent income
- Operating costs that regularly follow from wind power production
- Property tax for the wind power plant
- Tax depreciation of fixed assets connected to wind power production (investments before 2024)
- Loss on divestment of fixed assets
- Deferment interest (compensation for having to recognise investments from before 2024 as deductions over time)
- Costs incurred during construction
- Investment costs from 2024 onwards that would otherwise be subject to capitalisation
- Specially calculated company tax
= Resource rent income for the year (before deduction for previous years' negative resource rent income)

Gross resource rent income

Gross resource rent income is set to the sum of spot market prices multiplied by the actual production at the wind power plant in the relevant time periods. Production must be reported in kWh. The output must be stated in kWh.

Valued at contract price

Electricity supplied at a price other than the spot market price can be valued at the contract price when specific conditions are met. This applies to agreements on:

  • electricity delivered under a purchase contract entered into before 28 September 2022
  • electricity delivered to electricity suppliers in accordance with a long-term fixed-price contract, and which is delivered in accordance with a standard fixed-price agreement in the end-user market (standardised fixed-price agreements)
  • electricity delivered in accordance with a purchase contract entered into in the period 2024 to 2030, and which is connected to projects established in the period 2024 to 2030

If the enterprise owns a combination of hydropower plants and wind power plants, if it owns several wind power plants, or if it is part of a tax group with companies that own wind power plants or hydropower plants, the deliveries must be distributed among the various plants in accordance with specific rules.

If the agreement is terminated early, the gain or loss will be included in the resource rent income.

Hedged price

Electricity that is delivered at spot market price, but which is financially hedged according to an agreement entered into before 28 September 2022, is valued at a hedged price.

The enterprise finds the hedged price by valuing the electricity at the spot market price in the periods and volumes the plant produces. The enterprise must then calculate the gain or loss on the financial hedge each year based on the market development for electricity in that income year. This gain or loss must be added to or subtracted from the gross resource rent income.

If the enterprise owns several wind power plants or is part of a tax group with a company that owns wind power plants, the gain or loss must be distributed among the wind power plants in accordance with specific rules.

If the agreement is terminated early, the gain or loss for the income year and the remaining hedging period must be included in the resource rent income for the income year.

Other income included in resource rent income

  • gain on divestment of fixed assets used for wind power production
  • subsidies for the production of new wind power
  • income from issued electricity certificates
  • income from issued Guarantees of Origin (GO)

Deductions when calculating resource rent income

The taxpayer is entitled to a deduction from gross resource rent income for operating costs related to the wind power production.

Examples:

  • wages and other personnel costs for persons associated with the wind power production
  • maintenance costs
  • insurance costs
  • administrative costs
  • compensation to landowners and licensees for lost income from activities other than wind power that must cease in whole or in part upon the establishment of the wind power plant
  • losses on the divestment of fixed assets used in wind power production (and which are not covered by the cash flow tax)
  • costs of feeding electricity into the grid
  • costs for removing wind power plants and restoring areas according to the terms of the licence

Examples:

  • sales, transfer, and financial costs
  • costs for the purchase of land or other benefits to, for example, landowners or the municipality are also not deductible

The enterprise is only entitled to a deduction from the resource rent income for costs that are related to the actual wind power production. This means that the enterprise cannot necessarily claim a deduction for a cost from the resource rent income, even if the same cost entitles the enterprise to a deduction from ordinary income.

Costs that benefit the production of several wind power plants, or that benefit both wind power production and other activities, must be distributed according to specific rules.

Investment costs incurred before 1 January 2024 are deducted through depreciation.

Investment costs incurred from and including 1 January 2024 are deducted directly from the resource rent income (cash‑flow tax). The investment cost is deducted directly from the resource rent income in the income year in which the cost must be capitalised in ordinary income.

Cash flow tax

The resource rent tax on wind power is a cash-flow tax. When the enterprise calculates resource rent income, it may deduct investment costs directly if the costs would otherwise have to be capitalised in ordinary income.

For the enterprise to be entitled to a direct deduction for the investment cost from the resource rent income, the cost must be related to the power production. The right to deduct applies to both depreciable and non‑depreciable assets.

Examples of investment costs for a wind power plant that may be deducted directly include:

  • foundations
  • towers
  • wind turbines
  • cable systems or transformer stations
  • service buildings
  • construction roads
  • parking sites

Examples of costs that cannot be deducted directly include:

  • purchase of an existing wind power plant
  • purchase of land or other payments to, for example, landowners or municipalities

The investment cost can be deducted directly from the resource rent income in the year in which the investment becomes subject to the capitalisation obligation in ordinary income.

Depreciations

For investments that are subject to the capitalisation obligation before 1 January 2024, the cash flow tax does not apply. The enterprise is entitled to a deduction for such historical investment costs through depreciation and deferment interest. A condition for deduction is that the investment is related to wind power production.

Special rules apply to the calculation of the depreciation basis for existing fixed assets in the resource rent income. The depreciation base is depreciated in identical annual amounts over five years.

  • property tax for the wind power plant
  • deferment interest on fixed assets that are depreciated
  • specially calculated company tax

Negative resource rent income

If the deductions are higher than the gross resource rent income, the resource rent income will be negative. The negative resource rent income is carried forward with interest and will be deducted from next year's calculated resource rent income for the wind power plant.

Rates and key figures

The Norwegian Parliament, the Storting, stipulates the tax rates for resource rent income every year.

For 2025, it's set at 32.1 percent. Since a deduction is given for resource rent-related company tax, the effective tax rate will be 25 percent.

Renten brukes til:

  • beregning av fradrag for skattemessige verdier av driftsmidler knyttet til vindkraftproduksjonen pr. 1. januar og 31. desember i inntektsåret (venterente)
  • fremføring av negativ grunnrenteinntekt i vindkraftforetak
  • tilbakeføring av negativ grunnrenteinntekt ved realisasjon av vindkraftanlegg
  • fremføring av overskytende avgift på landbasert vindkraft

  • Stortinget fastsetter skattesatsen for grunnrenteinntekten hvert år.
  • Skattedirektoratet beregner årlig rentesatsen for grunnrenteinntekten.
    Måten renten skal beregnes på er fastsatt i forskrift (FSFIN §18-10-16) 

 

Deductions for production fee

Tax on onshore wind power (production fee) will be deducted from the assessed resource rent tax at the wind power plant. If the production fee exceeds the resource rent tax for the income year, the excess can be carried forward as a deduction in later income years.

Legal sources

The Tax Administration’s guide Skatte-ABC: On resource rent tax on onshore wind power (K-5 Power companies – onshore wind power) (in Norwegian only).

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