Business Operations in Norway (Portfolio 7280)

Tax Management Portfolio, Business Operations in Norway, contains information designed to enable foreign businesses to determine the best method of conducting their operations in Norway from both a tax and a general legal point of view and addresses the practical problems confronting foreign businesses operating in Norway.

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The Portfolio analyzes in detail the statutory and procedural framework of Norwegian income taxation as it applies to individuals and corporations, both resident and nonresident. The analysis also covers many of the other legal details vital to the organization of a Norwegian company. In addition to providing a detailed explanation of the Norwegian system of income taxation, the Portfolio discusses the local taxes, the value added tax and other taxes.


Business Operations in Norway was authored by the following experts.
Espen Nordbø

Espen Nordbø, cand. jur. University of Oslo 1993; partner at Advokatfirmaet Haavind AS.

Eva Linn Gjerlaug

Eva Linn Gjerlaug, Master in Law, University of Oslo 2010.

Table of Contents

Portfolio 7280-1st: Business Operations in Norway

 Portfolio Description


 Technical Advisors



 Detailed Analysis

 I. Norway — The Country, Its People and Economy

 A. Geography and Population

 B. Constitution/Government

 C. Economy

 D. Membership in International Organizations

 E. General Investment and Business Climate

 F. Judicial System

 G. Tax Legislation, Tax Authorities and Advanced Rulings

 1. Tax Legislation

 2. Tax Authorities

 3. Advance Rulings

 II. Operating a Business in Norway

 A. Foreign Investment Regulation

 B. Currency and Exchange Controls

 C. Trade and Commerce Regulation

 1. Imports and Exports

 a. Licenses and Quotas

 b. Custom Duties and Other Taxes

 2. General Regulation of Business

 a. Monopolies

 b. Mergers

 c. Restrictive Trade Practices

 d. Price Controls

 3. Intellectual Property Rights

 a. Introduction

 b. Patents

 c. Designs

 d. Copyrights

 e. Trademarks

 f. Domain Names

 g. Trade Names

 h. Sanctions

 D. Immigration Regulations and Labor Laws

 E. Financing the Business and Incentives

 III. Forms of Doing Business in Norway

 A. Principal Business Entities

 B. Limited Liability Company

 1. Formation

 a. Incorporators and Procedure

 b. Company Name

 c. Capital Stock

 2. Operation

 a. License

 b. Amendment of Articles and Increase and Reduction of Company Capital

 c. Acquisition of Treasury Stock

 d. Corporate Officers and Directors

 e. The General Meeting

 f. Directors' Meetings

 g. Books and Records

 h. Financial Statements

 i. Dividends and Other Distributions of Profits

 3. Statutory Merger

 4. Liquidation

 C. European Company

 D. Cooperatives

 E. Partnership

 1. Formation

 2. Administration

 3. Dissolution

 F. Branch of a Foreign Corporation

 1. Registration

 2. Liability

 3. Books and Records

 IV. Principal Taxes

 A. Income Tax

 B. Value Added Tax

 C. Employers' Social Security Contributions

 D. Social Security Contributions of Employees and the Self-Employed

 E. Tax on Wealth

 F. Stamp Duty

 G. Real Property Tax

 H. Trade Tax and Sales Tax

 I. Excise Tax

 J. Natural Resources Tax

 K. Petroleum Income Tax

 L. Economic Rent Tax

 M. Tonnage Tax

 N. Inheritance Tax

 V. Taxation of Domestic Corporations

 A. What Is a Domestic Corporation

 B. Corporate Income Tax

 1. Taxation of Worldwide Income

 2. Accounting

 a. General

 b. Accounting Periods

 c. Consolidated Returns

 d. Filing of and Public Access to Annual Reports

 3. Calculation of Gross Income

 a. General

 b. Capital Gains

 c. Share Options

 d. Dividend Income

 e. Income from Foreign Sources

 f. Income from a Controlled Foreign Corporation

 g. Company Group Contributions

 4. Business Expenses

 a. General

 b. Organizational Expenses

 c. Entertainment Expenses

 d. Rent

 e. Interest and Royalties

 f. Profit Distributions and Paid-in Capital

 g. Depreciation and Amortization

 h. Obsolete Equipment

 i. Charitable Contributions

 j. Capital Losses

 k. Bad Debts

 l. Inventory

 m. Non-deductible Business Expenses

 5. Tax Consequences of Mergers, Demergers, Changes in Legal Form, and Liquidations

 6. Capital Expenditures

 7. Loss Carry Forward and Carryback

 8. Tax Credits

 9. Tax Rates and Calculation of Taxable Income

 10. Assessment and Filing

 C. Other Taxes

 1. Dividend Tax

 2. Stamp Duty

 3. Value Added Tax and Sales Tax

 4. Trade Tax

 5. Real Estate Tax

 6. Local Taxes

 7. Employers' Contributions to National Social Security

 VI. Taxation of Oil and Gas Companies

 A. Introduction

 B. Geographical Scope and Activities Covered

 C. Norm Price

 D. Special Provisions Regarding Allowances

 E. Special Provisions Regarding Losses

 F. Exploration Costs

 G. Uplift (friinntekt)

 VII. Taxation of Hydro-Electric Power Companies

 A. General

 B. Depreciation

 C. Economic Rent Tax

 D. Natural Resources Tax

 VIII. Taxation of Shipping Companies — The Tonnage Tax Regime

 IX. Taxation of Foreign Corporations

 A. What Is a Foreign Corporation

 B. Determination of Taxable Income

 C. Method of Taxation

 X. Taxation of a Branch

 A. Determination of Taxable Income

 B. Method of Taxation

 C. Subsidiary Versus Branch

 XI. Taxation of Partnerships

 XII. Taxation of Other Business Entities

 A. Cooperatives

 B. Private Businesses (Sole Proprietorships)

 XIII. Taxation of Individuals — Residents

 A. Scope of Taxation

 B. Residents

 C. Determination of Gross Income

 1. Earned Income

 2. Business Income

 3. Pension Income

 4. Income from Capital

 5. Capital Gains

 D. Allowable Deductions and Credits

 E. Rates and Calculation of Taxable Income

 1. Earned Income

 2. Business Income

 3. Pension Income

 4. Income from Capital

 F. Assessment and Filing

 XIV. Taxation of Nonresident Aliens

 A. General

 B. Business Income

 C. Investment Income

 1. Income from Tangible Assets

 2. Income from Shares

 3. Interest

 4. Royalties

 D. Employment Income and Directors' Fees

 E. Pension Income

 F. Special Income Tax for Artists, Sportsmen, etc.

 G. Allowable Deductions

 XV. Inheritance Tax

 XVI. Net Wealth Tax

 XVII. Inter-Company Pricing

 A. Scope of Provisions for Adjustment of Intercompany Pricing

 B. Transfer Pricing Reporting and Documentation Requirements

 C. Determination of Arm's-Length Price

 D. Competent Authority

 XVIII. Special Provisions Relating to Multinational Corporations

 A. General

 B. Norway as a Holding Company Jurisdiction

 1. Choice of Business Form

 2. Participation Exemption

 a. General Conditions

 b. Shares in Companies Resident in the European Economic Area

 c. Shares in Companies Resident Outside the European Economic Area

 d. Foreign Legal Entities with a Norwegian Branch

 3. Withholding Tax on Interest and Royalty Payments

 4. Withholding Tax on Dividends

 a. Distributions to Companies Resident in the European Economic Area

 b. Distributions to Shareholders Covered Under a Tax Treaty

 5. Capital Gains on Shares

 6. Controlled Foreign Corporations

 XIX. Avoidance of Double Taxation

 A. Foreign Tax Credits

 B. Tax Treaties

 1. General

 2. Planning to Minimize Taxation of Business Income under Tax Treaties

 3. Taxation of Investment Income

 C. Tax Treaties with the United States

 1. Income Tax Treaty

 a. Reduced Withholding Tax on Dividends

 b. Tax-Free Interest and Royalty Payments

 c. Branch Taxation — Definition of Permanent Establishment

 d. Taxation of Offshore Activities

 2. Social Security Treaty

 3. Estate and Inheritance Tax Treaty

 4. The Organisation for Economic Cooperation and Development and Council of Europe Mutual Administrative Assistance Treaty

Working Papers

 Working Papers

 Table of Worksheets

 Worksheet 1 Income Tax Return for Individuals

 Worksheet 2 Corporate Income Tax Return

 Worksheet 3 Information Return for Norwegian Tax on Dividends

 Worksheet 4 Extract of Accounts

 Worksheet 5 Guidelines to Completing the Extract of Accounts

 Worksheet 6 Information About Contracts, Contractors and Employees

 Worksheet 7 Tax Return for Advance Assessment of Foreign Employee

 Worksheet 8 Application for Refund of Value Added Tax to Foreign Business

 Worksheet 9 List of Comprehensive Double Taxation Agreements and Related Protocols Signed by Norway as of March 1, 2012

 Worksheet 10 Table of Withholding Tax Rates

 Worksheet 11 Contact Details for Public Information Request/Response

 Worksheet 12 1971 Norway-United States Income and Capital Tax Treaty

 Worksheet 13 1949 Norway-United States Estate and Inheritance Tax Treaty