Norway: Norway’s 2019 budget sees corporate income tax dip

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Norway: Norway’s 2019 budget sees corporate income tax dip

Sponsored by

Sponsored_Firms_deloitte.png
Chapter X has brought a number of guidelines to consider for Luxembourg

Norway's Parliament passed legislative changes for the 2019 budget on December 20 2018, seeing notable changes to inbound investments, particularly a reduced corporate income tax (CIT) rate and stricter interest limitation rules (ILR).

Norway's Parliament passed legislative changes for the 2019 budget on December 20 2018, seeing notable changes to inbound investments, particularly a reduced corporate income tax (CIT) rate and stricter interest limitation rules (ILR).

Corporate income tax falls to 22%

The general CIT rate for the income year 2019 has been reduced from 23% to 22%. It will largely benefit most Norwegian industries, except for the financial industry and the energy and resources industry. This will also affect deferred tax assets and/or liabilities in the annual accounts.

Stricter interest limitation rules

Inspired by BEPS Action 4 report, Norway has extended the ambit of ILR. For companies considered a "group company", the ILR will now apply to interest expenses on all debt, not just interest on internal loans. For stand-alone companies (all companies not considered as a "group company"), only the interest cost on related-party debt may be limited. Under ILR, net interest expenses exceeding 25% of tax earnings before interest, tax, depreciation and amortisation (EBITDA) will be denied.

A group company is defined as a company that either:

  • Has been consolidated line-by-line in the outgoing balance of consolidated group accounts (prepared according to Norwegian generally accepted accounting principles (NGAAP) or general accepted accounting principles (GAAP) in an EU or European Economic Area state, US or Japan, or International Financial Reporting Standards (IFRS) or IFRS SME, in the accounting year before the income year); or

  • Would have been if IFRS had been applied (line-by-line consolidated).

  • For a group company, the rules only apply if the net interest expense for all Norwegian companies within the group (consolidated) exceed NOK 25 million ($2.9 million). For stand-alone companies, the corresponding threshold is NOK 5 million.

However, as a starting point, the ILR will not apply for a group company demonstrating that the equity ratio (after several adjustments have been made) of either the company itself or the Norwegian part of the group is equal to or better than the consolidated equity ratio in the group accounts that the company was consolidated into (in the accounting year before the income year), i.e. not thinly-capitalised compared to the overall group (a 2% deviation from the group's equity ratio is accepted).

Adjustments to the domestic definition of tax residency

Norway has adopted a new definition of "tax residency" in domestic law from January 1 2019, which could ultimately lead to a change in the tax residency status for Norwegian and foreign limited companies, among others.

Under the new legislation, companies incorporated under Norwegian corporate law will always be regarded as a tax resident in Norway, unless they are regarded as a tax resident in another country (based on their domestic law and the tie-breaker rule in a tax treaty with Norway).

Moreover, foreign-registered corporations that have their effective management (and control) in Norway will be considered a tax resident in Norway. Effective management (and control) is not limited to the decisions at the board level (which was the main focus under previous rule), but also the day-to-day management, where the directors of the board/management reside and have their daily work (and "other circumstances based on the company's organisation and business".) An example of "other circumstances" would be the place of the shareholder meetings.

The rule could lead to the challenging of the tax residency status for non-Norwegian companies owned by Norwegian groups, as well as Norwegian companies owned by foreign groups where management takes place outside Norway.

more across site & shared bottom lb ros

More from across our site

The political optics of the US’s carve-out deal are poor, but as the Fair Tax Foundation’s Paul Monaghan writes, it preserves pillar two’s guiding ethos
The big four firm reportedly sent ‘threatening’ correspondence to Unity Advisory over its hiring of ex-PwC partners; plus tax recruitment news from the week
Tom Goldstein, who was represented by US law firm Munger, Tolles & Olson, denied wilfully cheating on his taxes and blamed errors on his staff
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
The profession is fundamentally restructuring itself around what tax and accounting work should be, a Thomson Reuters leader told ITR
The big four firm is consolidating 16 entities across the region to create a single 6,000-partner behemoth
Brazil’s tax reform unifies consumption taxes to simplify rules, centralise administration and reduce legal uncertainty
The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
Gift this article