Dual Residence in Norway: How Tax Treaties Decide Your Residency Status

If you have ties to more than one country, you may face dual tax residency. Norway’s tax laws combined with international treaties ensure you don’t pay double tax. This guide explains how tax treaties determine residency, what the rules mean for income, and how taxpayers in Norway can avoid paying tax twice in 2025 and 2026.

📌 What Is Dual Residence?

Dual residence happens when you meet the residency criteria of both Norway and another country. For example:

• You spend more than 183 days in Norway in a 12‑month period, making you a Norwegian resident under domestic law.
• At the same time, you are considered a resident in another country because of family ties, permanent home, or economic interests.

⚖️ How Tax Treaties Break the Tie

When dual residence occurs, Norwegian tax treaties (based on OECD standards) decide which country has primary taxing rights. The tie‑breaker rules follow this order:

1. Permanent Home: Where do you have a home available?
2. Center of Vital Interests: Where are your family, work, and economic ties strongest?
3. Habitual Abode: In which country do you regularly live?
4. Nationality: If the above factors don’t decide, your citizenship may.
5. Mutual Agreement: If none of the above resolves the issue, Norwegian and foreign authorities negotiate a solution.

🌍 Practical Scenarios

Example 1: Norwegian Work Contract + Foreign Family Home

A worker spends 200 days in Norway in 2025 but maintains a permanent home and spouse in Germany. The treaty likely deems Germany as the country of residence since the center of vital interests remains there.

Example 2: Long-Term Stay with Housing in Both Countries

An individual rents an apartment in Oslo and owns a flat in Spain. If they spend more time in Norway and have stronger work ties here, Norway may win residency under the treaty rules.

💰 Tax Implications of Dual Residence

• Avoiding Double Taxation: The treaty ensures you are not taxed twice on the same income.
• Foreign Tax Relief: If taxed abroad, you may claim a credit in Norway up to the treaty’s limits.
• Pensions: Many treaties give Norway taxing rights on Norwegian-source pensions, but exemptions may apply.
• Capital Gains: Rules vary, but typically Norway taxes gains from Norwegian assets, even if you are a dual resident.

✅ Steps If You Suspect Dual Residence

1. Check Norway’s 183/270 day rule for residency.
2. Review whether your other country also considers you a tax resident.
3. Consult the Norwegian tax treaty with that country.
4. Document your days in each country and proof of permanent home.
5. Apply for relief through Skatteetaten if you are taxed in both countries.