Norway Corporate Tax Guide

Corporate Tax Rate — 22%

• Flat rate: A single 22% rate applies to all corporate taxable income. There are no progressive brackets or reduced rates for small companies. The rate has been stable at 22% since 2019, reduced from 28% in 2013 through gradual cuts.
• Taxable income: Business profits as computed under ordinary accounting principles (regnskapslovgiving) with tax adjustments. The main adjustments include: depreciation differences (accounting vs. tax), non-deductible expenses (fines, gifts, 3% of entertainment costs), tax-exempt income (fritaksmetoden income), and group contributions.
• Tax return (næringsoppgave): The corporate tax return (RF-1167 / næringsoppgave) is filed via Altinn annually. The deadline is 31 May following the income year. The return includes financial statements, tax adjustments, and calculation of taxable income. Most companies have a calendar year, but fiscal years ending 30 June can also be used.
• Tax on dividends to shareholders: Dividends paid by the company to individual shareholders are subject to a 22% withholding tax (kildeskatt på utbytte), reduced under tax treaties. The shareholder includes the gross dividend in capital income (alminnelig inntekt) but receives a skjermingsfradrag (risk-free rate allowance) — only dividend income above the risk-free rate is taxed. See our Investment Income Guide → for details.

Fritaksmetoden (Participation Exemption)

• Purpose: The fritaksmetoden prevents economic double taxation of corporate profits — profits are taxed at the corporate level (22%) and again when distributed to shareholders as dividends. For corporate shareholders, 97% of dividends and capital gains on shares are exempt from tax (but 3% is taxable as a non-deductible cost). The effective tax rate on inter-corporate dividends is therefore: 22% × 3% = 0.66%.
• Qualifying shares: The exemption applies to shares in companies resident in Norway or in EEA countries, provided the shareholder owns at least 10% of the shares (or the shares are held as business assets). A minimum holding period of 2 years applies for some categories. Shares in companies in low-tax jurisdictions (skatteparadis) outside the EEA are excluded from the exemption.
• Corresponding rule for losses: 97% of losses on qualifying shares are non-deductible (symmetrical treatment). This prevents companies from recognising losses on share investments while gains are 97% exempt. The remaining 3% of losses are deductible.
• Foreign dividends: Dividends from non-EEA companies may also qualify for the fritaksmetoden if the foreign company is subject to a corporate tax rate of at least 15% and is not in a low-tax jurisdiction. Otherwise, foreign dividends are fully taxable with a foreign tax credit (Fradrag for utenlandsk skatt) available under domestic rules or tax treaties.

Depreciation (Avskrivning) — Declining Balance Method

• Declining balance (saldoavskrivning): Norway uses a declining balance depreciation system for tangible assets. The depreciation is calculated on the remaining tax value (saldo) each year. Key annual rates:
  - 20% — Machinery, plant, equipment, industrial buildings (Group B/D)
  - 14% — Cars, buses, trucks, tractors (Group C)
  - 10% — Goodwill, patents, copyrights (Group E)
  - 8% — Office furniture, computers (Group F)
  - 5% — Aircraft, ships (Group B spesial)
  - 2% — Commercial buildings (Group H)
• Pooled asset system: Assets are grouped into saldo groups. Each group accumulates a closing balance (ingående saldo + additions − disposals − prior depreciation). The depreciation is limited to the closing balance each year. Disposal proceeds are deducted from the group balance — if proceeds exceed the balance, the excess is taxed as ordinary income.
• New assets — half-year rule: Assets acquired during the year benefit from a half-year depreciation — only 50% of the standard rate applies in the year of acquisition. This prevents a full year's depreciation on assets purchased late in the year.
• Immediate expensing (småforenkling): Small companies with turnover under NOK 5 million can immediately expense (full depreciation in year 1) assets costing up to NOK 30,000 per item, and can also use simplified rules for consumables and maintenance.

Group Taxation and Loss Relief

• Group contribution (konsernbidrag): Companies within a Norwegian tax group (parent owns >90% of shares) can make group contributions (konsernbidrag) — deductible for the paying company and taxable for the receiving company. This allows losses and profits to be offset within the group, achieving tax consolidation without formal filing of a consolidated return.
• Loss carry-forward (fremførbart underskudd): Tax losses can be carried forward indefinitely with no time limit. However, if there is a change of ownership (ownership merger or more than 50% of shares change hands) combined with a change in business activity, the loss carry-forward may be limited or forfeited. Losses arising before the ownership change may be restricted under the underskuddsfremføring ved eierskifte rules.
• Tax on dividends to shareholders: Corporate profits distributed as dividends to individual shareholders attract 22% withholding tax (kildeskatt på utbytte), reducible under tax treaties. The shareholder-level tax is applied in addition to the 22% corporate tax. For foreign shareholders, the withholding tax may be reduced under an applicable tax treaty (typically 5–15% on substantial holdings, 15% on portfolio holdings).
• Thin capitalisation: Norway has thin capitalisation rules — interest deductions are limited where the lender has a controlling interest (direct or indirect) in the borrower, and the debt exceeds 30% of EBITDA (earnings before interest, tax, depreciation, and amortisation). Excess interest can be carried forward up to 10 years. The rules apply to related-party debt exceeding NOK 5 million.

For VAT/MVA rates and registration, see our VAT Guide →. For wealth tax on corporate shares held by individuals, see our Wealth Tax Guide →. For capital gains on shares and property, see our Capital Gains Tax Guide →.