The Norwegian Directorate of Taxes changes its opinion on employee share incentive schemes

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

The Norwegian Directorate of Taxes changes its opinion on employee share incentive schemes

Sponsored by

Sponsored_Firms_deloitte.png
tart

Daniel M. H. Herde and Lene Bergersen of Deloitte Norway explain an interpretative statement from the Norwegian Directorate of Taxes, in which the Directorate changes its view on the Kruse Smith model.

On January 1 2022, the Norwegian Directorate of Taxes issued two statements regarding the acquisition of shares by employees, and whether the capital gains will be taxed as salary income. Both statements are explained in an earlier article by Deloitte for ITR. 

One of the statements specifically addressed a type of scheme where an employee pays only part of the purchase price upon acquisition of the shares, and the residual amount is settled upon future disposal of the shares. This is known as the Kruse Smith model. This statement received criticism for challenging the Kruse Smith model by applying stricter requirements than the Norwegian Supreme Court. 

 

 

 

 

On March 28, the Directorate of Taxes therefore published an updated interpretative statement in which the Kruse Smith judgment (Rt. 2000 p. 758) was given added weight. For a description of the Kruse Smith judgment, please refer to our earlier article.

  

 

The updated statement

 

In the statement from January 1, the Directorate stated that the obligation to repay the residual amount must be “genuine” to be regarded as a loan rather than a taxable discount (taxable as salary income). The key is that the employee must have an unconditional obligation to repay the loan. In the Directorate’s view, a loan would not be unconditional if the repayment was dependent on the economic development of the company. 

  

 

Based on this statement, it would be challenging to apply the Kruse Smith model going forward, because employees under such schemes would normally not be obliged to pay the residual amount, if the company developed negatively. 

  

 

In the updated statement, the Directorate applied a less strict view and generally confirmed the Supreme Court’s reasoning in the Kruse Smith judgment. In summary, the Directorate confirmed that an employee may acquire the shares at a value far below the marked value, as long as the employee commits to repay the residual amount upon disposal of the shares. 

  

 

Furthermore, the Directorate confirmed that the employees can receive “downside protection” by not having to repay the residual amount (the loan) in the case that the company develops negatively or goes bankrupt. 

  

 

However, if the residual amount is waived (in other words, if the loan is forgiven), the benefit will be taxed as salary income. Regarding interest on the residual amount, the Directorate confirmed that the obligation to pay the residual amount would normally be covered by the tax rules on subsidised loans under employment (Norwegian Tax Act sections 5-12 paragraph 4), where the normal interest rate is lower than market rate. 

  

 

Taxation as salary income may first apply if the rate is lower than the normal interest rate under such employment loans. 

  

 

Based on the renewed statement, the Kruse Smith model still has support and may be applied going forward. 

   

 

 

Daniel M. H. Herde 

Partner, Deloitte Norway

E: dherde@deloitte.no 

  

 

Lene Bergersen

Associate, Deloitte Norway

E: lebergersen@deloitte.no 

 

more across site & shared bottom lb ros

More from across our site

Peru’s approach to TP is increasingly at odds with OECD-style profitability policies, exposing multinational groups to asymmetric tax adjustments
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
The DS Advocates partner discusses career reinvention, tax disputes and why advisory and litigation experience should complement one another
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
Shared transaction semantics, governed data and reusable ERP design may prove the most significant benefits of the UK's move to Peppol
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues
Pillar two may be raising less than expected, but professor René Matteotti says the regime is still changing multinational tax behaviour
Multinationals importing goods into Brazil may need to align TP files and customs documentation more closely as authorities gain new tools to challenge related-party transactions
The private equity-backed deal hands Grant Thornton immediate and impressive US scale, but World Tax data suggests the firm still has work to do to gain recognition
Gift this article