The Aider Legal Blog

Should your business register for VAT in Norway?

Written by Synnøve Sørdal - Lawyer & Partner | 11. November 2021

Your business must register for VAT in Norway once its VAT-liable turnover exceeds NOK 50,000 within a rolling 12-month period — but only if your activities count as being carried out "in" Norway rather than merely directed "toward" the Norwegian market. Which one applies depends on where ownership of your goods transfers, how you market to Norwegian customers, and whether your services can be delivered remotely.

Getting this assessment wrong is a common and costly mistake for foreign companies entering the Norwegian market. Register too late, and you risk back-payment of VAT, interest, and penalties; register when you don't need to, and you take on reporting obligations and, in many cases, a Norwegian VAT representative you didn't need. The rules are not always intuitive, because Norwegian VAT law does not spell out exactly when a foreign business is "doing business in Norway" — that line has been drawn by case law and tax authority guidance instead. This article walks through the turnover threshold, the "to" versus "in" Norway distinction, the leading court decision on the topic, how the rules apply to services and rental of goods, and when you need a Norwegian VAT representative.

What is the VAT registration threshold in Norway?

Any business carrying out VAT-liable activity in Norway must register in the Norwegian VAT Register once turnover from that activity exceeds NOK 50,000 within any rolling 12-month period — not a calendar year, so a company can cross the threshold at any point during its financial year. Once registered, a business is treated the same as a Norwegian company for VAT purposes: it charges VAT at the standard rate of 25% (with reduced rates for certain goods and services), and it typically files VAT returns six times a year. Input VAT refunds are usually processed within 21 days. 

How does VAT apply when importing goods to Norway?

Goods brought into Norway are subject to import VAT, collected through customs when the goods cross the border. In most cases, it's the Norwegian recipient of the goods — not the foreign seller — who is responsible for the import VAT, which means the foreign seller often has no Norwegian VAT registration obligation from the import itself. There's a separate framework for retailers and platforms selling low-value goods directly to Norwegian consumers: the VOEC scheme (VAT On E-Commerce).

Also read: VAT on e-commerce in Norway.

What is the difference between selling “to” and doing business “in” Norway? 

This is the question that trips up most foreign companies, because the Norwegian VAT Act doesn't define it directly. The distinction has instead been shaped by case law and guidance from the Norwegian Tax Administration — most notably a 2006 Supreme Court ruling known as the Ifi Oy case (Rt. 2006 p. 364). 

  Selling "to" Norway Doing business "in" Norway
Where ownership/risk transfers  At or before the Norwegian border  After the goods cross the border 
VAT registration triggered?  Generally no Yes, once turnover exceeds NOK 50,000  Yes, once turnover exceeds NOK 50,000 
Typical marketing footprint  Limited or general international marketing   Norwegian-language marketing, .no domain, Norwegian phone number 
How the transaction reads to the customer  As a purchase from abroad  As a purchase from a Norwegian-based business 

Example: What did the Ifi Oy case decide?

In the Ifi Oy verdict, the foreign company sent packages of photo prints by regular mail to private Norwegian persons. The goods were not considered delivered until they reached the customers’ mailboxes. This was an important factor in establishing liability for the foreign company to register in Norway and compete with Norwegian businesses on equal terms. It was also significant that the foreign company clearly and in several manners directed its business towards the Norwegian market and that the agreements (ordering of photo prints) took place inside Norway. 

Also read: Import to Norway - VAT and customs

What other factors affect your VAT registration obligations? 

Beyond where ownership transfers, the Tax Administration and the courts look at the overall picture of how Norwegian-facing the business appears: the intensity and targeting of marketing toward Norwegian customers, whether the business uses a .no domain, whether it lists a Norwegian phone number, whether it corresponds with customers in Norwegian, and — more broadly — whether a Norwegian customer would reasonably perceive the business as Norwegian-based rather than foreign. Many other elements can factor into this evaluation; our more detailed practical overview of Norwegian VAT for foreign companies goes through them in depth. 

Where is a service considered delivered for VAT purposes? 

Services are harder to place than goods, because there's no physical ownership transfer to point to. The key question becomes whether the Norwegian connection is strong enough on its own facts. As a general rule, services that can be delivered remotely — advisory work, software development, and similar services that don't require the provider to be physically present — do not trigger a Norwegian VAT registration obligation, even if the end result is used in Norway. 

Also read: How to choose the right corporate structure in Norway

How does VAT apply to renting out goods in Norway?

Renting out goods to Norwegian customers can create a registration obligation even for a foreign lessor with no other presence in Norway, particularly if the goods are already located in Norway when the lease begins. A 2017 statement from the Tax Administration points to several relevant factors: whether payment is made in NOK (a stronger indicator of a Norwegian connection than a foreign currency), where the goods are delivered, when and where risk transfers to the customer, and what the customer is permitted to do with the goods. If a Norwegian customer is contractually restricted from taking the goods out of Norway, that generally points toward a Norwegian VAT obligation; if the customer can freely use the goods internationally, it generally doesn't. 

Do you need a Norwegian VAT representative?

If your business is VAT-liable in Norway but has no fixed place of business there, you generally need to appoint a Norwegian-resident VAT representative to handle your registration and VAT returns. Businesses established in the following EU/EEA countries are exempt from this requirement.

However, enterprises from the following EU/EEA countries are exempt. They can register without a representative: Belgium, Bulgaria, Denmark, Croatia, Czech Republic, Cyprus, Estonia, Faroe Island, Finland, France, Germany, Greece, Greenland, Hungary, Iceland, Italy, Latvia, Lithuania, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and the United Kingdom. 

Aider Legal is a VAT representative for foreign companies engaged in VAT-liable activity in Norway.

Should your business register for VAT in Norway?

There's rarely a simple yes-or-no answer — it depends on where ownership transfers, how your business markets itself, whether you're selling goods, services, or rentals, and how a Norwegian customer would perceive your business. Getting it wrong in either direction is costly, whether that means unpaid VAT and penalties or an unnecessary compliance burden. If you're planning to enter the Norwegian market, or you're not certain whether your current activities already trigger a registration obligation, it's worth getting this assessed properly before it becomes a problem. This is also closely tied to how you structure your business in Norway more broadly, since your corporate setup affects your VAT position too.

With over 30 years of experience advising foreign companies doing business in Norway, our lawyers can assess your VAT registration obligation and handle your registration, representative arrangement, and ongoing compliance.