On 7 October 2026, the Støre government presented its proposed state budget for 2027. Below are the key matters concerning tax and duties.
Tax-paid-in capital
The current rules on tax-paid-in capital are resource-intensive and open to unwanted tax planning. The reason is that the tax position of paid-in capital carries over on a share transfer, regardless of what the new shareholder paid for the share.
On 15 October 2025, the Ministry of Finance circulated a proposal for amendments for public consultation, with a deadline of 15 January 2026. Two solutions were outlined. Alternative 1 provides tax exemption for previously paid-in capital, capped at the shareholder's cost price. Alternative 2 provides tax exemption up to the cost price, regardless of what was previously paid in.
The consultation shows broad support for changing the rules. However, the consultation bodies disagree on which alternative is best. The Tax Commission (NOU 2026: 9) supports a change but does not take a position on which alternative should be chosen.
The proposal remains under consideration by the Ministry. No changes are therefore proposed to take effect from 1 January 2027, as originally envisaged in the consultation paper. The Ministry notes that the general anti-avoidance rule can be applied to tax-motivated arrangements.
Price board for aquaculture
The resource rent tax on aquaculture was introduced with effect from 2023, and standard prices for sales income are the main rule under the resource rent tax regime. On 5 June 2026, Parliament requested the government to put forward a proposal to discontinue the standard price and Price Board arrangement for aquaculture, with effect from the 2027 income year.
The Ministry is now mapping alternatives to the current Price Board model, with the aim of facilitating a correctly determined resource rent tax while keeping administrative costs down for both the companies and the tax authorities.
The Ministry is considering measures along two main tracks. The first alternative is that the Price Board is discontinued and resource-rent taxpayers themselves determine the market value at the cage edge. The second alternative is that binding tax settlement prices continue to be set, but with adjustments to the current model.
The Ministry estimates that a discontinuation would likely reduce resource rent tax revenues by NOK 1.2 billion for 2027.
To prevent the resource rent tax from being eroded, the government considers it necessary to continue the Price Board for the 2027 income year.
The government intends to circulate a proposal for consultation in spring 2027, with a view to a further assessment in the 2028 state budget.
VAT on the donation of foodstuffs
On 20 June 2025, Parliament requested the government to ensure that it does not pay for businesses to destroy food rather than give it away, in connection with the new Food Waste Act adopted in June 2025.
The Ministry notes that a VAT exemption for the distribution of foodstuffs on a charitable basis has existed since 2016, provided the recipient is registered in the Central Coordinating Register for Legal Entities.
The exemption works as intended, and there is little debate about its scope. The Ministry therefore considers it unnecessary to adjust the rules.
Circular economy - taxes and duties
An expert group presented 79 recommendations in 2025 to promote circular activities. The Ministry assessed several proposals in the tax and duties area, the most central of which are mentioned below. The remaining proposals outside the tax and duties area are addressed by the Ministry of Climate and Environment.
With the aim of reducing mortality in aquaculture and giving fish farmers incentives to implement measures to reduce fish losses, the government announced in the 2026 state budget a duty on lost fish that was to be introduced with effect from 1 January 2027. However, the preparatory work requires more time, and the duty will not be introduced from that date. Any proposal will be circulated for consultation.
To increase the cost of landfilling waste, and thereby stimulate reuse and material recycling, the expert group proposed a separate landfill duty. The government is assessing the proposal and will come back to Parliament on the matter.
Furthermore, the government proposes lowering the VAT threshold for electric vehicles from NOK 300,000 to NOK 150,000, with a view to full VAT from 1 January 2028. This follows the expert group's general recommendation to phase out exemptions and reduced rates in VAT, in line with earlier assessments by the VAT Committee, the Tax Committee and the Tax Commission.
On 19 June, parliament requested the government to assess a concrete and practically feasible model for a duty exemption on the sale of used goods, by 1 November 2027. This builds on the expert group's recommendation of a time-limited support scheme, either as a direct grant or as a duty exemption, and a technical simplification of the margin scheme so that the margin is calculated in aggregate per period rather than per item. The government will assess this and come back to the parliament.
Goods under NOK 3,000 handled through the VOEC scheme for VAT are in practice exempt from customs duty on clothing and textiles, giving foreign online retailers a competitive advantage. On this occasion, the government proposes reducing the remaining customs duty on clothing and textiles to a single common rate of 5% to strengthen the competitiveness of Norwegian retailers.
Document duty - demolition and rehabilitation of existing buildings
The current special rule provides for duty on the site value only on the first transfer of a newly constructed building or a building under construction. Conversion and rehabilitation fall outside this and are subject to duty on the full sale value. The Tax Commission (NOU 2026: 9) pointed out that this can make it cheaper to demolish and build new than to rehabilitate, and the expert group on the circular economy recommended on the same basis that the special rule be repealed.
The Ministry has considered two alternatives. One is to abolish the special rule, so that new buildings are fully subject to duty. The other is to extend it to also cover rehabilitated buildings.
An abolition could increase revenue by around NOK 1.5 billion annually but would likely increase the price of newly constructed buildings, reduce housing construction, and create new duty-technical challenges related to the timing of the transfer of buildings under construction.
An extension could reduce revenue by around NOK 1.5 billion. It would also require difficult distinctions between rehabilitation, conversion and new construction, which the Ministry considers may be uncertain to control adequately, since the assessment would largely have to be based on the taxpayer's own information.
The Ministry considers that there are few building projects where the duty is actually decisive for the choice between demolition and rehabilitation and therefore proposes no changes to the document duty.
Residence rules in the national population register act
On 1 June 2026, parliament requested the government to put forward a proposal to modernise the residence provisions in the National Population Register Act. The background was that the rules for spouses, parents and commuters are perceived as complex and outdated, and that they create challenges for persons with a legitimate reason to change or retain their legal residence, for example to stand for election.
The Ministry considers that the rules have been stable for a long time and serve their purpose. A change would have consequences in several legal areas, including tax, the residence obligation under the Concession Act, and eligibility rules under the Election Act and the Local Government Act. The Ministry also points out that more flexible rules could weaken the block grant to less central municipalities, since commuting mostly goes towards the most central municipalities. The Ministry therefore does not put forward a proposal to change the residence provisions.
Measures to improve shareholder register quality
On 27 May 2025, parliament requested the government to assess measures against register errors, following a private member's bill on strengthening efforts against economic crime. This included, among other things, control of amended information, the ability to reject information where errors are suspected, and progress on an event-based register of shareholders.
The Ministry of Finance proposes start-up funding for a new, coordinated register of shareholders and a modernised shareholder taxation system (SAMOA). The register will automatically retrieve information from companies' share registers, and the Brønnøysund Register Centre will be responsible for it. In parallel, work is underway on a similar concept for event-based ownership registration for real property at the Norwegian Tax Administration and the Norwegian Mapping Authority.
From January 2027, a national cross-agency centre against economic crime is planned. The Ministry of Finance will provide a status update in the 2028 state budget.
