Corporate tax in Norway: The basics for foreign companies

All Norwegian companies and foreign enterprises doing business in Norway are subject to Norwegian corporate tax, generally at 22%. Higher rates apply to specific industries — finance (25%), petroleum (78%), hydroelectric power (67% marginal), aquaculture (47% marginal), and onshore wind farms (47% marginal). Liability may be reduced or exempted depending on tax treaties and permanent establishment status. This article covers the basics of what foreign companies with business projects in Norway must know. 

What are the corporate tax rates in Norway (2026)?

* Also applicable to the Norwegian branch of a foreign enterprise 
** The dividend withholding tax rate is zero on distributions to corporate shareholders genuinely established within the EU/EEA. The rate is also normally reduced according to a tax treaty.
*** A 15% withholding tax on interest, royalties, and certain lease payments to related entities resident in a low-tax jurisdiction was introduced in 2021

Also read: Doing business in Norway-An brief overview of company obligations

When does a foreign enterprise become liable for corporate tax in Norway?

According to domestic tax law, Norway's threshold for becoming subject to corporate tax is rather low. The starting point is that any foreign enterprise will become subject to Norwegian corporate tax if it conducts business activities within Norway or if it hires employees to work in Norway.

However, Norway has tax treaties with about 90 countries, which may provide an exemption from Norwegian tax liability. Therefore, an assessment of tax liability must be made specifically for each foreign enterprise and based on the relevant tax treaty.

The basic rule in the tax treaty is that a foreign enterprise becomes subject to tax if it has a so-called “permanent establishment” or “PE” in Norway. A PE may exist e.g. if the foreign enterprise:

• Has a fixed place of business in Norway through which the business of the enterprise is wholly or partly carried on
• Is engaged in a building site or construction or installation project that endures for more than a given number of months, e.g. 6 or 12 months
• Is represented by a dependent person or agent in Norway that is acting on behalf of the enterprise and has, and habitually exercises, the authority to conclude contracts in the name of the enterprise or
• Is engaged in petroleum-related business activities on the Norwegian continental shelf for more than in the aggregate of, e.g., 30 days.
  
  

What are transfer pricing rules in Norway?

Norwegian tax authorities are aware that multinationals may be tempted to reduce the taxable profit in Norway when determining the transfer prices between group companies. Adjusting transfer prices has become a targeted area for tax auditors. It is, therefore, essential that intra-group prices can be documented as arm’s length.

Certain intra-group transactions must be reported when filing the corporate tax return, and in some cases, the enterprise should annually prepare transfer pricing documentation.

Also read: Transfer pricing: Deciding factors when choosing a method

What are Norway's anti-tax avoidance rules?

According to provisions of the Tax Act, the tax office may disregard transactions or structures if the dominant motive is to save taxes and the tax effects of entering into the transaction or structure are regarded as disloyal to the tax system.

Who must file Country-by-Country Reporting in Norway?

The Norwegian Country-by-Country Reporting (CbCR) rules imply that Norwegian entities that are part of a multinational group of companies with consolidated turnover exceeding NOK 6.5 billion in the financial year, must notify the tax office when filing the tax return.

How and when do you file corporate tax return in Norway?

A foreign company subject to corporate tax, according to domestic Norwegian tax law, must file the corporate tax return. This obligation exists even though the enterprise may be exempted from corporate tax liability pursuant to a tax treaty unless the tax administration has accepted an application for non-filing the relevant year.

The deadline for filing the corporate tax return is the end of May the year after the end of the income year.

A corporate tax return must be filed electronically via www.altinn.no using approved software—paper filing is not accepted.

Also read: Taxes in Norway - employee taxation

Need help with your corporate tax in Norway or other obligations?

A foreign enterprise doing business in Norway may have several compliance obligations, including registration in various public registers and reporting to various public authorities. E.g., payroll reporting is due monthly, and VAT reporting is due every second month.

Failure to comply will normally result in heavy fines. We are happy to assist you if you need help with your corporate tax in Norway or have other Norwegian compliance-related questions.