Norwegian tax and tax reporting obligations for foreign businesses

Cross‑border commercial activity is steadily increasing, and many foreign enterprises now conduct operations in Norway or target the Norwegian market. Even limited activity, such as remote work performed from Norway or occasional sales may trigger Norwegian tax, VAT, payroll, or corporate reporting obligations. It is therefore essential to assess these requirements at an early stage to ensure compliance.

This article provides a high‑level overview of the most common obligations that may apply to foreign businesses. The specific requirements will depend on the nature and extent of the activity and must be assessed on a case‑by‑case basis.

Registration in Norway
Foreign companies will in most cases be required to register with the Norwegian Business Register (Norwegian: Brønnøysundregistrene) before commencing activities in Norway. 

In most cases, foreign enterprises will consider one of the following registration options: 

• Registering a Norwegian registered foreign business (NUF) which could be compared to a branch of the foreign company and is not a separate legal entity
• Incorporating a Norwegian limited liability company (AS)

To ensure the most suitable structure in Norway local advisors should be consulted to ensure the most suitable option. 

The comments in this article focus primarily on NUF registrations.

As the registration process may take 1–2 months, it is advisable to initiate it well in advance of commencing activity in Norway. Once registered, the NUF will receive a Norwegian business organisation number, which is required for all tax and VAT reporting.

Corporate income tax
The threshold for being deemed to conduct taxable activity in Norway is very low. Under the Norwegian Taxation Act most activities, either direct or via employees working remotely, will in most cases be considered taxable. 

If the activity is taxable under the Taxation Act, the company is required to file a corporate income tax return, regardless of whether tax is ultimately payable under the tax treaty. 

Some countries require a separate registration for tax purposes to submit corporate income tax return. However, in Norway there are no such requirements as the business organisation number is used for any tax reporting and the activity itself will decide if a corporate income tax return is required.

Permanent establishment (PE)
A relevant tax treaty may limit Norway’s right to tax the income if the activity does not constitute a permanent establishment (PE). In such case, the company may not be subject to Norwegian corporate income tax. Nevertheless, a corporate income tax return is still required under Norwegian law.  

If no permanent establishment exists, a nil-return with an attachment explaining the business activity and the exemption is often accepted by the tax authorities. It is also possible to apply for an exemption from filing, although such exemptions are granted for one year at a time and must be renewed annually.

VAT
All supplies of goods and services within the Norwegian territorial boarder are subject to VAT. VAT registration is required when VAT-liable sales exceed NOK 50,000 within any 12-month period. Some goods and services may be considered exempt VAT or not subject to VAT. Those who merely provide goods or services not subject to VAT will not be entitled to register for VAT.

There are two types of VAT registrations available: 

Ordinary VAT registration
This is the standard scheme for businesses with VAT‑liable sales in Norway. Key features include:

Requires a Norwegian business organisation number
Allows deduction of Norwegian input VAT (subject to documentation requirements)
VAT returns are submitted bi‑monthly

VOEC registration for VAT
This simplified scheme applies only to foreign businesses with no presence in Norway and only for:

-          B2C sales of remotely deliverable services (including electronic services)
-          B2C sales of goods valued below NOK 3,000

Certain goods, e.g., foodstuffs and goods subject to excise duties, are excluded from the VOEC scheme and could require an ordinary VAT registration. 

B2B sales are also excluded from the VOEC scheme, and an ordinary VAT registration could be required. 

VOEC is a pay‑only scheme, meaning suppliers cannot deduct input VAT. Refunds of Norwegian input VAT may be applied for separately, although processing times currently exceed one year.

A key advantage of VOEC is that goods covered by the scheme are not subject to customs declaration or customs duties. VOEC VAT returns are submitted quarterly.

A key advantage of VOEC is that goods covered by the scheme are not subject to customs declaration and customs duties. For sellers of products otherwise subject to customs duties, e.g., apparel, this provides a significant advantage.  

VAT returns for VOEC must be submitted quarterly.

VAT rates
The VAT rates in Norway are the following:

·         25 % - Standard VAT rate

·         15 % - Foodstuffs

·         12 % - Passenger transport, hotel accommodation etc.

·         0 % - Books, newspapers etc.

Payroll and employer obligations
Foreign employers with employees working from Norway are subject to Norwegian payroll reporting obligations from day one, regardless of the duration or extent of the work.

If the employees do not have Norwegian ID-number, the employees must register at the tax office to obtain a D-number which is an ID number for foreign employees working temporarily in Norway.

The salary will, among others, be subject to withholding tax according to the tax deduction card, employers’ national insurance contributions, pension contributions etc. In addition, the employees’ work and working conditions must be in accordance with the Norwegian Working Environment Act. 

Annual accounts and audit
Foreign entities registered in Norway may be required to submit annual accounts, although exemptions apply in certain circumstances.

Audit obligations arise if the business meets any of the following criteria:

• Annual sales revenue exceeds NOK 7 million
• Balance sheet assets exceed NOK 27 million
• Average number of employees exceeds 10 full-time equivalents

If any one of these thresholds is exceeded, an audit is mandatory.

HSE (HMS) Card
Businesses operating in the cleaning, car care, goods transport, construction, or building sectors must obtain HSE cards for all employees.

Reporting of employees, contracts, contracting parties
Assignments to foreign contractors and the use of foreign employees must be reported to the Assignment and Employee Register.

Bookkeeping and SAF-T (Standard Audit File-Tax)
Entities with obligations to submit corporate income tax returns, VAT returns, or annual accounts must comply with the Norwegian Bookkeeping Act (Bokføringsloven) and maintain accounting records in accordance with the Standard Audit File for Tax (SAF-T) requirements.

Labor legislation
If foreign personnel are working in/from Norway the business must ensure that all terms and conditions comply with the Norwegian Working Environment Act.

Ultimate beneficial owner
The ultimate beneficial owner(s) of the business must be reported.