Exit tax – what happens to your shares when you leave Norway?

The shares are treated as if sold at market value the day before you leave. On a personal emigration there is a NOK 3 million threshold on the total latent gain, and the tax can be paid at once, in twelve interest-free annual instalments, or in full after twelve years with interest. Since 7 October 2024, 70% of any later dividend has to go towards paying the deferred tax down.

The rules have changed three times – older explanations are out of date

If you have built up value in shares while living in Norway and then move out for tax purposes, Norway can calculate tax on the gain even though you have not sold the shares. This is called exit tax (utflyttingsskatt). The rules changed substantially from 20 March 2024, were tightened further from 7 October 2024, and inheritance got new rules from 1 January 2025. So many older explanations online are now misleading – particularly about the threshold, the payment deferral and what happens if the value later falls.

It is tax emigration that counts

Exit tax does not arise merely because you notify the population register or board a plane. It becomes relevant when you stop being tax resident in Norway under Norwegian domestic law, or are to be treated as tax resident in another country under a tax treaty. Your registered address does not settle this on its own.

What is actually taxed?

The rules treat the relevant assets as if sold at market value the day before you leave. For a share the starting point, simplified, is: Market value on leaving − tax base − any unused shielding = latent gain How the shielding deduction builds up year by year decides how much can be deducted here. The rules from 20 March 2024 are aimed at the increase in value accrued while you were tax resident in Norway.

The threshold is NOK 3 million

On a personal emigration you get a threshold of NOK 3,000,000 on the total latent gain. Only the part above three million is caught. With a latent gain of NOK 2,500,000 the exit tax is in principle nil. With NOK 4,000,000, the taxable base is NOK 1,000,000. That is a substantial difference from the older rules, and it means many smaller holdings fall outside entirely.

A transfer to someone abroad has a completely different threshold

You do not have to move yourself for section 10-70 to apply. If you live in Norway but transfer relevant assets to a person, company or other arrangement resident abroad, exit tax can be triggered. Here the threshold is NOK 100,000 of net latent gain. Unlike the three-million threshold this works as a trigger: once it is exceeded, the whole net gain can be caught.

Moving outside the EEA, losses are treated worse

On a move to the EEA or Svalbard, latent losses can be included in the net calculation under the applicable conditions. If you move outside the EEA, latent losses are not included in the same way. Where you move to can therefore matter a great deal for the calculation itself – not just for the security required.

Which assets are covered?

The rules go wider than shares in your own AS. They cover shares in Norwegian and foreign companies, units in securities funds, share savings accounts, fund accounts and capital insurance, interests in partnerships, employee options, subscription rights, share options, warrants and several other financial instruments. A review of the whole portfolio – not just the business – is therefore necessary before the move.

A worked example

For an ordinary share gain for a personal shareholder the tax rate in 2026 is 37.84% after any shielding. That follows from 22% tax on general income and an uplift factor of 1.72. Assume the latent share gain on leaving is NOK 3,950,000. Threshold: −NOK 3,000,000. Taxable latent gain: NOK 950,000. Exit tax calculated: 950,000 × 37.84% = NOK 359,480.

You do not have to pay it all at once

For an emigration under the new rules there are in practice three choices: 1. Pay the whole tax straight away. 2. Pay it in 12 annual instalments. One twelfth is paid each year, and those instalments are interest-free. 3. Defer the whole payment to the end of the 12-year period. Interest then runs until payment. For a move or transfer outside the EEA, adequate security is a condition of deferral. Within the EEA, security is required only where a specific assessment shows a real collection risk.

A dividend can force the exit tax to be paid

For emigrations and transfers from 7 October 2024 an important rule arrived. Where you have deferred payment and receive a dividend or another relevant distribution, 70% of the distribution has in principle to be used to reduce the unpaid exit tax. With NOK 359,480 of deferred tax and a dividend of NOK 200,000, 70% is NOK 140,000, which in principle has to go towards repayment. If you also pay Norwegian or foreign tax on the distribution itself, the repayment is reduced so that the tax and the repayment together do not exceed 100% of the distribution. «Distribution» is broader than an ordinary dividend and can include a loan taxed as a dividend. A tax-free repayment of previously paid-in capital is not in itself a distribution that triggers the 70% rule.

A later fall in value will not save you

Under today's rules the original exit tax is not automatically reduced because the shares later fall in value. The valuation at the date of leaving can therefore matter a great deal financially. For unlisted companies the market value should be documented carefully – see What is my business worth? If the shares are realised while payment is deferred, the right to continued deferral falls away for the tax attaching to that asset.

What if you move back to Norway?

If you become tax resident in Norway again within 12 years of the end of the year of assessment, and still own the shares, the exit tax on those shares can fall away. Tax already paid can in such cases be repaid with interest under the rules. Where part of the tax has been finally settled because of distributions, that is not repaid simply because you move home. Instead the tax base can be adjusted. If you move back after 12 years, the ordinary lapse option is gone. Where the tax has been settled and the shares are still held, the base is adjusted so that the increase in value already taxed on exit is not taxed again on a later sale.

Gifts, inheritance and moving on again have their own rules

A gift, gift sale or other transfer with a gift element to a recipient outside Norway can affect the right to continued deferral. A transfer to a recipient in Norway can in some cases continue the position with continuity, but does not mean the original tax claim simply disappears. Death has its own rules. An heir in Norway and an heir abroad can be treated differently, and from 1 January 2025 a distribution from a Norwegian estate to a recipient abroad can also trigger exit tax. If you first move within the EEA and then on outside it, the security requirements and any earlier loss relief may have to be reassessed.

Three different exit taxes should not be confused

A personal shareholder – section 10-70. The rules this article is about. The company itself moves – section 10-71. Where a Norwegian company becomes tax resident in another state, separate rules apply. See also Effective management An asset leaves Norwegian taxing jurisdiction – section 9-14. Relevant where operating assets, intangibles or other assets lose their connection to Norwegian taxing jurisdiction.

The reporting is part of the tax claim

Exit tax is reported in its own fields in the tax return. Where payment is deferred there is also a continuing duty to provide information. After the changes from 7 October 2024, Skatteetaten can in certain cases assess exit tax up to 15 years later where the information was not given. Not reporting is therefore not a way of avoiding the claim – it only lengthens the period in which it can arrive.

Document the values before you move

For a founder or business owner with unlisted shares there should be documentation of the latest annual accounts and updated interim accounts, normalised profitability, debt and cash, relevant share transactions, issues and external financing, the valuation model and its assumptions, and the historical tax base and unused shielding. Before moving you should know which assets are covered, what the documented market value is, how large the latent gain is, whether it exceeds the threshold, whether you are moving within or outside the EEA, whether the tax is to be paid now, annually or after twelve years, whether the company can be expected to pay large dividends after you leave, and what happens if you later move on or move back. We can map the shares and tax positions, retrieve tax bases and shielding, prepare the financial valuation basis and calculate how the payment options affect your cash position. For larger emigrations, questions of treaty residence, valuation disputes or complicated transfers abroad, the structure should be quality-assured by a tax lawyer or another specialist before the move.

This is general guidance, not advice on your specific case. Deadlines, rates and amounts change – always check the current rules, or get in touch with us.

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