NOKUS - Norwegian-controlled foreign company

Norwegian private individuals and companies that alone or together with other Norwegian taxpayers own or control at least half of a foreign company that is domiciled in a low-tax jurisdiction should be taxed for their share of the foreign company’s profit. The Norwegian owner is in this context called the “partner”.  

The rules apply to foreign companies that correspond to Norwegian private limited companies (AS) or similar, as well as some assets that are managed abroad, typically trusts. Taxation must take place even if the foreign company has not distributed dividend to Norwegian taxpayers. 

Exemptions from NOKUS taxation may apply if a tax treaty exists, or if the company is domiciled in an EEA country. 

What you need to do

Company tax return with business information

Both private individuals and companies are jointly responsible for submitting the company tax return with business information.  

The company tax return must be submitted online. From and including the income year 2023, the company tax return must be submitted via an accounting or annual accounts system that supports the submission of the company tax return for NOKUS.  

The company tax return must, among other things, include information about:  

  • the partner’s ownership interest in the company 
  • information about the partner’s purchase of the ownership interests 
  • allocation of income and wealth between the partners 
  • carry forward deficits on the ownership interest from previous years 
  • dividend (distribution) to the partners 
  • the partner’s realisation (sale) of ownership interests/shares in the company 

For the submission of a new self-assessment for previous years, RF-1245 Selskapsmelding for NOKUS (Company tax return for NOKUS - in Norwegian only), RF-1234 Selskapets melding over deltaker i NOKUS (Company’s statement of partners in NOKUS - in Norwegian only) and RF-1167 Næringsoppgaven (Income statement) and other relevant RF forms must be used when submitting the company tax return.  

New NOKUS must be assigned a registration number prior to submission. This number is obtained by sending an email to [email protected]. Enter the following information: 

  • Name of the company
  • The company’s purpose 
  • Date of establishment 
  • Norwegian address 
  • NOKUS country 
  • The Norwegian representative who should have access to Altinn (name with national registration number and/or Norwegian company with organisation number) 

All NOKUS are processed in the Large Business Division in Moss. Please send any questions you may have to [email protected].

What the partners need to do 

Submit the tax return

As partner in the company, you must submit the ordinary tax return by the set deadline. Income and wealth are entered under the topic “Wealth and income in a business assessed as a partnership”. Amongst other things, the partners must fill in:  

  • share of wealth in the company 
  • share of the company’s profits  
  • distribution 
  • gains and losses upon realisation (sale) of ownership interests/shares 

For the submission of a new self-assessment for previous years, RF-1246 Deltakerens melding over formue og inntekt i NOKUS (Partner’s statement of capital and income in NOKUS - in Norwegian only), must be used when submitting the company tax return.