Important information

Vil du hjelpe oss med å bli bedre? Vi jobber med å gjøre det lettere å finne fram på nettsidene våre, og trenger din hjelp.

Exit tax

If you've moved abroad or to Svalbard, or transferred assets to someone living abroad, you might be subject to tax. This applies to the increase in value of your assets up to the point of moving or transferring. 

Here's what you need to know about the rules for your transfer or move.

Does this apply to me?

Exit tax might apply to you if you have:

What affects the tax liability:

  • What you owned at the time of transfer or moving and the value you had accumulated. 
  • When the transfer or move happened, as the rules have changed several times in recent years.

Important!

It's important to understand the rules that apply to your transfer or move.   

Moved or transferred assets on or before 19 March 2024

 

Rule changes and dates to be aware of 

  • The rule on tax liability for transferring assets only applied to gifts and gift sales to a spouse who’s tax resident abroad. 
  • The tax liability lasts for five years from the time of the exit tax. 

  • The rule on tax liability for transferring assets now also applies to gifts and gift sales to relatives and in-laws who are tax resident abroad. 
  • The tax liability no longer has a time limit; previously, it was five years. 

  • The rule on tax liability for transferring assets now applies to gifts and gift sales to all individuals, companies, or entities that are resident or domiciled abroad.

 

Exit tax applies to

  • Shares in Norwegian or foreign companies. 
  • Units in securities funds, including fixed income funds, equity funds, and combination funds. 
  • Options in employment relationships.  
  • Ownership interests in companies assessed as partnerships.  
  • Financial instruments where the underlying asset is subject to exit tax. This includes share forwards, share futures, contracts for difference (CFDs), financial futures, share options (also outside employment), subscription rights, foreign ETFs, and warrants.  
  • Assets in foreign pension savings schemes when considered as a regular investment account. This includes American schemes like IRAs and 401(k)s. Only the assets in the account subject to exit tax must be included.  

If you had such assets at the time of moving abroad or transferring, you must provide information about the assets in your tax return, in the specific fields for exit tax.

You must provide the information in the tax return that applies to the day before the move or transfer occurred. For example, if you changed residence under a tax treaty on 1 January 2024, you must provide exit tax information in the 2023 tax return. 

Exit tax does not apply to shares in a share savings account and investment fund account (with capital insurance). 

What you need to do

In your tax return, you must:  

  • Explain why exit tax applies to you. 
  • Indicate if you want to defer the payment of the tax liability. 
  • Calculate and report the latent gain or loss for each asset. If you've bought shares multiple times in the same company, you need to calculate the gain or loss for each share trade. Read more about the FIFU principle in the guide Skatte ABC (in Norwegian only)

If the net latent gain exceeds NOK 500,000, you must pay exit tax. If you've moved to or transferred assets to another EEA country or Svalbard, your losses are deductible if the net latent loss exceeds NOK 500,000. 

The tax liability is conditional, meaning the tax is not final until the asset is divested. If you've chosen to defer the payment of the tax claim, you must provide updates during the period the tax liability lasts.  

Latent gain is the increase in value of the asset from when you bought it to the day before you moved or transferred the asset abroad.  

Latent loss is the decrease in value of the asset from when you bought it to the day before you moved or transferred the asset abroad. 

Latent gains and losses are generally calculated in the same way as a regular sale. However, there are special rules regarding the opening value of assets subject to exit tax.

All amounts are in NOK

 

Market value at the time of moving abroad

Purchased for

Risk-free return allowance

Latent gain/loss

Shares

4,250,000

2,500,000 

25,000

1,725,000

Securities
fund

   765,000

   450,000

  4,500

   310,500

Ownership interest
in a
business assessed
as a partnership - DLS

2,431,000

1,430,000

 14,300

   986,700

Options

   210,000

   300,000

   3,000

  - 93,000
No deduction is given for realised losses outside the EEA

Foreign
shares

1,190,000

   700,000

   7,000

  483,000

Total/taxable
part

 

 

 

3,412,200

 

The amount that must be secured if outside the EEA

3,505,200

If you want to defer the payment of the tax claim, you generally need to provide security for the claim, such as a pledge of shares or real estate.  

If you've moved to or transferred assets to another EEA country or Svalbard, you're exempt from this requirement. However, you must provide security if you've moved to or transferred assets to Ireland, Cyprus, or Liechtenstein. 

If you need to provide security for the tax claim, the Tax Administration will inform you on how to proceed. 

If you've deferred the payment of the tax claim, you must keep the Tax Administration updated as long as the deferral lasts. This includes any changes regarding you or the recipient of the transferred assets, and the assets the tax is based on.

If there are no changes, you must confirm this to us once a year. For certain events, you must provide information continuously. 

If your situation has not changed

Every year by 30 April, you must:

  • inform us which country you or the recipient of the transferred asset is resident in
  • confirm that you or the recipient of the transferred assets still hold the assets
How to do it

You'll receive a questionnaire each year that you can fill out and send to us. You'll find the form in your inbox when you log in.

Non-digital users and those who moved before 1 January 2022 must send the information via the contact form or by letter

If your situation has changed

You must notify us within two months.

If you or the recipient of the transferred asset: 

  • no longer have the asset, for example, due to sale or transfer as a gift 
  • move from an EEA country to a country outside the EEA 
How to do it

To provide the new information, you log in to your tax return, make changes, and re-submit the tax return. It's the previous tax return that should be resubmitted, and the information should be entered in the fields for exit tax. 

If you moved abroad or transferred assets on or before 1 January 2022, you can use the contact form or form RF-1314

If you've paid tax on the gain in another country, you can claim a credit deduction in the exit tax. You must attach proof of the foreign tax. 

If you've realised latent losses, you can only deduct them if you can prove that you have not received a deduction for the loss in another country. To show this, you can attach the tax return and tax assessment notice from the country you live in to the Norwegian tax return. 

If you moved or transferred assets on or before 28 November 2022, the conditional tax liability lasts for five years. The tax liability on assets you or the recipient still hold will lapse after this period. 

If you've provided security for the tax claim, you can request that it be released when the five-year period has expired.

If you have losses or have not requested a deferral on gains, you do not need to provide us with information continuously or annually.

However, because you might be entitled to a deduction or refund of tax paid on gains in some cases, you should still provide us with information if: 

  • You realise a loss and have not received a deduction for the loss in another country. This only applies if you live within the EEA when the loss is realised.
  • You realise a gain and the actual gain is lower than the previously determined latent gain.
  • You realise a gain and have paid tax on the gain in another country. 
  • You move back to Norway, causing the tax liability to lapse. The same applies if you have tax liability as a resident in Norway and move to a country with which Norway does not have a tax treaty. 
  • The recipient of the transferred asset moves to Norway or transfers the asset back to the donor. 
  • More than five years have passed since the tax liability arose, causing the tax liability to lapse. This only applies if you moved or transferred assets abroad before 29 November 2022.

Moved or transferred assets on or before 20 March 2024

 

Rule changes and dates to be aware of

There have been significant changes to the regulations, including:

  • The threshold amount has changed, and there is a distinction between transfers and relocations. 
  • The tax must be paid within 12 years, unless you move back to Norway before the 12 years have passed. 
  • Exit tax will only be calculated on values accumulated while you were tax resident in Norway. 
  • Share savings accounts and investment fund accounts are subject to exit tax. 
  • Deductions for losses are granted immediately but can be reversed within 12 years if you move or transfer out of the EEA or back to Norway. 
  • If the person subject to exit tax dies, the exit tax must be paid. However, this does not apply if the asset is transferred to heirs who are resident in Norway, in which case the tax claim can lapse. If a personal heir who’s tax resident abroad inherits the asset, the heir can take over the tax liability and deferral of the deceased person. 
  • Exit tax will no longer be adjusted for value changes after relocation or for tax paid abroad. 
  • The Tax Administration can require you to provide security for the tax claim even if you move or transfer assets to other EEA countries. 
  • If you move back to Norway after 12 years, the opening value of the assets you still own will be adjusted to their market value at the time of relocation.  

In addition to the changes effective from 20 March, the following rules also apply:

  • If you've deferred tax payment and receive a distribution (dividend) from a company, 70 percent of the distribution must go towards repayment of the tax claim. If you pay tax on the distribution in Norway and abroad, the repayment of the exit tax claim should be limited so that you do not pay more than 100 percent of the distribution in total.
  • Distribution includes any form of free transfer of values from the company to the shareholder or participant, as well as loans from the company to the shareholder or participant or their related parties.  
  • If you've received a distribution and paid exit tax because of this, the opening value of the assets must be adjusted if you move back to Norway before 12 years have passed. 
  • If you transfer assets subject to exit tax, you must make payments towards the deferred tax even when the asset is transferred to companies or other entities abroad. All types of transfers require you to make payments towards the deferred exit tax on the transferred asset. 
  • If you don't provide information about exit tax in your tax return, the Tax Administration can assess exit tax up to 15 years after the relocation or transfer. Previously, the deadline was five years. 

In addition to the changes effective from 20 March and 7 October, the following rules also apply:

  • Tax liability for transferring assets now also applies when the transfer occurs as inheritance from a Norwegian decedent's estate. This can be to a person, company, or entity that is tax resident or domiciled abroad. The decedent's estate is liable for tax, and the heir who receives assets automatically takes over the tax liability and payment deferral. 

 

Exit tax applies to

  • Shares in Norwegian or foreign companies. 
  • Units in securities funds, both the interest component and the share component.  
  • Share savings accounts. 
  • Endowment insurance (investment fund account). 
  • Options in employment relationships.  
  • Ownership interests in companies assessed as partnerships.  
  • Financial instruments where the underlying asset is subject to exit tax. This includes share forwards, share futures, contracts for difference (CFDs), financial futures, share options (also outside employment), subscription rights, foreign ETFs, and warrants. 
  • Assets in foreign pension savings schemes when considered as a regular investment account. This includes American schemes like IRAs and 401(k)s. Only the assets in the account subject to exit tax must be included.  

If you had such assets at the time of moving abroad or transferring, you must provide information about the assets in your tax return, in the specific fields for exit tax. You must provide the information in the tax return that applies to the day before the move or transfer occurred. For example, if you changed residence under a tax treaty on 1 January 2024, you must provide exit tax information in the 2023 tax return. 

What you need to do if you

In your tax return, you must: 

  • Explain why exit tax applies to you. 
  • Enter when the move from Norway or transfer occurred. 
  • Indicate whether you want to pay the tax claim immediately, pay it in instalments over a period of 12 years after the relocation or transfer, or defer the payment of the entire tax liability for 12 years. If you're entitled to a deduction for latent losses, you cannot choose to defer the deduction. 
  • Calculate and report the latent gain or loss for each asset. If you've bought shares multiple times in the same company, you need to calculate the gain or loss for each share trade. Read more about the FIFU principle in the guide Skatte ABC (in Norwegian only)

Latent gain is the increase in value of the asset from when you bought it to the day before you moved or transferred the asset abroad.  

Latent loss is the decrease in value of the asset from when you bought it to the day before you moved or transferred the asset abroad. 

Latent gains and losses are generally calculated in the same way as a regular sale. However, there are special rules regarding the opening value of assets subject to exit tax.

If the assets you’ve transferred have a net latent gain exceeding NOK 100,000, you must pay exit tax on the entire gain. If you've transferred assets to another EEA country or Svalbard, you're entitled to a deduction for losses if the net latent loss exceeds NOK 100,000. 

If you transfer assets out of the EEA, we add up all latent gains. Losses are not included. 

All amounts in NOK

 

Market value at the time of transfer

Purchased for

Risk-free return allowance

Latent gain/loss

Transfer of shares to A

500,000

400,000

4,000

  96,000

Transfer of shares to B

400,000

300,000

3,000

  97,000

Transfer of shares to C

450,000

500,000

5,000

- 55,000

Total

 

 

 

138,000

 

 

 

 

 

Taxable part

 

 

 

138,000

All amounts in NOK.

 

Market value at the time of transfer

Purchased for

Risk-free return allowance

Latent gain/loss

Transfer of shares to A

500,000 

400,000 

4,000 

  96,000 

Transfer of shares to B

400,000 

300,000

3,000 

  97,000 

Transfer of shares to C

450,000 

500,000 

5,000 

- 55,000 
The loss is not included in the calculation

Total

 

 

 

193,000 

 

 

 

 

 

Taxable part

 

 

 

193,000 

You get a basic deduction of NOK 3,000,000 in the calculated latent gain or loss. This means that only the part of the total gain or loss exceeding NOK 3 million is subject to exit tax or eligible for deduction. 

If you move or transfer assets to another EEA country or Svalbard, we add up all latent gains and losses to arrive at the net latent gain before deducting the NOK 3 million basic deduction. You also have the right to deduct net latent losses exceeding the basic deduction.  

If you move or transfer assets out of the EEA, we add up all latent gains. Losses are not included.  

All amounts in NOK.

 

Market value at the time of moving abroad

Purchased for

Risk-free return allowance

Latent gain/loss

Asset 1

4,250,000 

2,500,000 

25,000 

1,725,000 

Asset 2

   765,000 

   450,000 

  4,500 

   310,500 

Asset 3

2,431,000 

1,430,000 

14,300 

   986,700 

Asset 4

   210,000 

   300,000 

  3,000 

 - 93,000 

Asset 5

1,190,000 

   700,000 

  7,000 

   483,000 

Total

 

 

 

3,412,200 

Basic deduction

 

 

 

3,000,000 

Taxable part

 

 

 

   412,200

All amounts in NOK.

 

Market value at the time of moving abroad

Purchased for

Risk-free return allowance

Latent gain/loss

Asset 1

4,250,000

2,500,000

25,000

1,725,000

Asset 2

   765,000

   450,000

  4,500

   310,500

Asset 3

2,431,000

1,430,000

14,300

   986,700

Asset 4

   210,000

   300,000

  3,000

 - 93,000 
The loss is not included in the calculation

Asset 5

1,190,000

   700,000

  7,000

   483,000

Total

 

 

 

3,505,200

Basic deduction

 

 

 

3,000,000

Taxable part

 

 

 

   505,200

Information heirs must provide if someone subject to exit tax dies 

If a person who previously moved abroad or transferred assets to someone living abroad and was subject to exit tax dies, the right to defer payment no longer applies.  

If the asset subject to exit tax is transferred with full continuity to heirs resident in Norway, including the same opening value as the deceased person, the tax claim still lapses.  

In such cases, the heir must contact the Tax Administration to adjust the deceased person's exit tax.  

If the asset subject to exit tax is transferred to heirs resident abroad, the heir can choose to take over the deceased's tax positions, meaning the payment obligation for unpaid exit tax, the duty of disclosure, opening values, etc. 

As an heir, you must determine latent gains and losses in your tax return.  

In your tax return, you must: 
  • explain why exit tax applies to you 
  • enter when the transfer occurred 
  • indicate whether the tax claim must be paid in instalments over the remaining part of the 12-year period, or if the payment should be deferred until the end of the 12-year period
  • enter the deceased's calculated latent gains or losses for each asset in your own tax return 

If you have not received a tax return, you can find information about what you need to do here.

No Norwegian D number or national identity number? Read about how identification number are issued.

When assets are transferred to an heir who’s tax resident in another country, a decedent's estate and heirs must provide the following information.

Decedent's estate 

If the estate of a deceased person who was tax resident in Norway transfers assets to a person, company, or entity that is tax resident or domiciled abroad, the estate will be liable for tax on latent gains and losses. 

In the tax return, the decedent's estate must:
  • report information on latent gains and losses
  • provide information about who has received the inheritance

The date of tax liability is the day before the assets were transferred.     

Heirs 

At the time of the transfer, the heir takes over both the tax liability and the duty of disclosure. As an heir, you must determine latent gains and losses.  

In your tax return, you must: 
  • Explain why exit tax applies to you. 
  • Enter when the transfer occurred. 
  • Indicate whether you want to pay the tax claim immediately, pay it in instalments over a period of 12 years after the transfer, or defer the payment of the entire tax claim for 12 years. If you're entitled to a deduction for latent losses, you cannot choose to defer the deduction. 
  • Calculate and report the latent gain or loss for each asset. If the deceased person's bought shares multiple times in the same company, you need to calculate the gain or loss for each share trade. Read more about the FIFU principle in the guide Skatte ABC (in Norwegian only). 

If you have not received a tax return, you can find information about what you need to do here.

No Norwegian D number or national identity number? Here you can read about how identification numbers are issued.

If the assets you’ve transferred have a net latent gain exceeding NOK 100,000, you must pay exit tax on the entire gain. If you've transferred assets to another EEA country or Svalbard, you're entitled to a deduction for losses if the net latent loss exceeds NOK 100,000. 

If you transfer assets out of the EEA, we add up all latent gains. Losses are not included. 

Examples of calculation of latent gains

All amounts in NOK.

 

Market value at the time of transfer

Purchased for

Risk-free return allowance

Latent gain/loss

Transfer of shares to A

500,000 

400,000 

4,000 

  96,000 

Transfer of shares to B

400,000 

300,000

3,000 

  97,000 

Transfer of shares to C

450,000 

500,000 

5,000 

- 55,000 
The loss is not included in the calculation

Total

 

 

 

193,000 

 

 

 

 

 

Taxable part

 

 

 

193,000 

All amounts in NOK

 

Market value at the time of transfer

Purchased for

Risk-free return allowance

Latent gain/loss

Transfer of shares to A

500,000

400,000

4,000

  96,000

Transfer of shares to B

400,000

300,000

3,000

  97,000

Transfer of shares to C

450,000

500,000

5,000

- 55,000

Total

 

 

 

138,000

 

 

 

 

 

Taxable part

 

 

 

138,000

If you want to defer the payment of the tax claim, you generally need to provide security for the claim, such as a pledge of shares or real estate.  

If you've moved to or transferred assets to another EEA country or Svalbard, you only need to provide security if there's a real risk that taxes and any calculated interest cannot be collected. 

If you need to provide security for the tax claim, the Tax Administration will inform you on how to proceed.

You need to keep us updated on what's happening

As long as you have tax liability, you must keep us updated on what happens to you or the recipient of the transferred asset, and about the assets on which the tax has been assessed.

Answer a few questions and you'll know what to do