On 7 October 2026, the Government presented its proposed state budget for 2027. Below are the main proposed changes to corporate tax for Norwegian companies.
The Government proposes to maintain the general corporate tax rate unchanged at 22 % in 2027. This means companies will face the same nominal tax rate as in previous years.
Skattefunn is a support scheme that provides a tax deduction for costs related to research and development projects chosen by the businesses themselves. In recent years, the Norwegian Tax Administration has uncovered misuse, including cases where certain actors have reported inflated deduction bases that can trigger direct payouts.
To limit misuse of the Skattefunn scheme, the Ministry of Finance circulated a proposal for consultation on 30 April 2026. The proposed rule changes are, for the most part, proposed to be implemented.
This means that costs incurred before a Skattefunn project is approved can no longer be deducted. Under the previous rules, such costs could be deducted if the project was approved within the same income year.
An aggregate deduction cap of NOK 25 million is introduced for corporate groups. A transitional rule ensures that projects that take effect before the rule change are not affected.
The geographic limitation on the right to deduct is tightened. For research and development costs incurred outside the EEA, a deduction will only be available where the costs are incurred in a country with which Norway has a tax treaty or an agreement on exchange of information.
To strengthen oversight of the scheme, it is also proposed to expand information sharing between the Research Council, which processes applications, and the Tax Administration, which audits the deductions.
The proposed changes are intended to take effect from the 2027 income year.
The Government also proposes changes to the Top-up Tax Act, which implements the global minimum tax (Pillar Two) into Norwegian law and is intended to ensure that large corporate groups are taxed at a minimum of 15 % regardless of where the business is conducted. Among other things, the changes anchor new Safe Harbour rules in the Act.
For the aquaculture industry, it is proposed that the right to deduct the fee on farmed fish in the resource rent tax be limited to the same aquaculture permits that are subject to resource rent tax.
The Government is following up on a request from Parliament to expand the share savings account scheme.
Today, private individuals can use a share savings account to invest in shares, equity certificates and equity funds within the EEA, but only where the securities are listed on a stock exchange or another regulated market. Euronext Growth is not regarded as a regulated market, but as a multilateral trading facility (MTF), and therefore currently falls outside the scheme. The Government's proposal would thus make considerably more Norwegian growth companies available for saving through a share savings account.
As elsewhere under the share savings account scheme, gains and dividends can be reinvested without current taxation for as long as the funds remain in the account. At the same time, the Government signals that further expansion of the scheme is being considered over time, including whether additional types of securities, such as bond funds, can be included in the scheme.
The Ministry of Finance proposes a start-up appropriation in the 2027 budget for a new, coordinated shareholder register (SAMOA), which will draw updated information on an ongoing basis from companies' share registers instead of today's annual reporting. For limited liability companies, this could over time mean more frequent reporting obligations upon changes of ownership, even though the annual shareholder register statement will be discontinued. For now, this is only a start-up appropriation – the actual roll-out remains to be carried out and is not expected to be ready until 2030.
The proposals presented in the 2027 national budget are not final at this stage. The budget marks the start of this autumn's negotiations in Parliament where tax and duty changes traditionally become subject to political discussions and adjustments before the final budget is adopted.