Exit Tax in Norway: Rules for Expats and Shareholders Moving Abroad

Planning to move abroad while holding Norwegian shares or options? Norway’s exit tax regime is one of the most important rules for expats and shareholders. This blog explains who is affected, how the exit tax works, and what you must do to remain compliant when relocating outside Norway.

📌 What Is Exit Tax in Norway?

The Norwegian exit tax applies when an individual ceases to be a tax resident of Norway but owns shares or stock options. The tax is levied on the latent (unrealised) gains of those assets to ensure Norway captures tax revenue from wealth created during residency.

👤 Who Is Subject to Exit Tax?

• Individuals holding shares or options with total gains exceeding NOK 500,000.
• Expats moving abroad after being tax resident in Norway.
• Individuals transferring shares to close family members living abroad.
• Both Norwegian citizens and foreign nationals once considered residents under domestic rules.

📊 How Exit Tax Is Calculated

The taxable amount is determined based on the market value of the shares or options on the last day before you are deemed a non-resident. Here’s a simplified example:

• Shares purchased: NOK 300,000
• Value on departure: NOK 900,000
• Latent gain: 900,000 − 300,000 = NOK 600,000
• Tax (22% general income tax, adjusted if dividends): ≈ NOK 132,000

📅 Recent Changes to the Exit Tax Rules

Until 2022, the tax liability could lapse if the shares were not sold within five years of leaving Norway. However, from 29 November 2022, the five-year exemption has been removed. Now:

• Tax liability applies regardless of when the shares are sold.
• Transfers to close family abroad are also taxed.
• Authorities are tightening enforcement to prevent avoidance.

⚖️ Interaction with Tax Treaties

If you move to a country that has a double tax treaty (DTT) with Norway, the treaty may affect how exit tax applies. However, Norway usually retains the right to tax gains accrued during Norwegian residency. Foreign tax credits may reduce double taxation, but careful planning is essential.

💡 Strategies to Manage Exit Tax

• Plan Ahead: Review your share portfolio and potential gains before moving.
• Check Tax Treaties: Ensure your new country has a favorable DTT with Norway.
• Consider Timing: If possible, realise gains before moving abroad.
• Professional Advice: Consult a tax advisor to assess options for minimising liability.

📌 Key Takeaways

Norway’s exit tax ensures that unrealised share gains built up during residency are taxed before moving abroad. With recent changes removing exemptions and broadening coverage, expats and shareholders should take proactive steps to understand their liability and explore available reliefs.