Do you own a foreign company? How to report it correctly
Start with who owns what. If you own the shares personally, the wealth value, the dividends and any gain go into your own tax return – the company's bank account does not. If a Norwegian holding company owns them, everything belongs in that company's accounts. Where the company is a CFC, current income taxation comes on top, and intra-group transactions can trigger their own reporting.
The hard part is knowing what actually has to be reported
Owning a company abroad is entirely lawful. But if you or your Norwegian AS are taxable in Norway, the reporting obligations do not disappear because the company has a foreign registration number and bank account. Do you report the shares? The company's bank account? The dividend? The company's whole profit? Loans between the companies? The answer depends on whether the shares are owned by you personally or by a Norwegian AS, whether the foreign company is an ordinary company or a CFC, whether the company is itself tax resident in Norway, whether it carries on business through a permanent establishment here, and what transactions take place between related companies.
Do you own the shares personally?
If you are tax resident in Norway, you are as a starting point taxable here on income and wealth both in Norway and abroad. So check that foreign shares and the relevant income are correctly entered in the tax return. That normally means the wealth value at year end, the dividends received and any realised gain or loss.
Do not trust the pre-filled tax return blindly
Norwegian banks report many foreign securities held in Norwegian custody accounts. But shares held directly with a foreign bank or broker are normally not pre-filled through Norwegian third-party reporting. Something not appearing in the tax return does not mean it is tax-free. It only means nobody has told Skatteetaten about it yet.
How are foreign shares valued?
For personal taxpayers the valuation discount on shares is 20% in 2026. For unlisted foreign shares the general rule is 80% of the estimated sale value at the end of the income year. The taxpayer can in some cases claim the Norwegian substance or wealth value method where the necessary basis under Norwegian rules can be established.
What about dividends and share gains?
For a personal Norwegian shareholder the shareholder model applies as a general rule to qualifying foreign shares too. The uplift factor in 2026 is 1.72, giving 37.84% effective tax on taxable dividends and gains after any shielding. Where the foreign country has withheld tax on the dividend, credit relief can be available – but it has to be claimed, and documented.
If a Norwegian holding company owns the foreign company
Then it is Holding AS that owns the shares. The shares, the dividends and any gains or losses belong in Holding AS's accounts and tax return – not as foreign shares directly in your personal return. How much tax Holding AS pays depends among other things on the participation exemption.
The company and the shareholder are two different persons
If Foreign Holding Ltd has NOK 2 million in its bank account, you should normally not report that as your private foreign bank account. The money belongs to the company. You own the shares in the company. So it is the share value you report personally. The same applies to the company's receivables and securities portfolio: they are the company's assets, not the shareholder's. Where the company is a CFC, a separate current income and reporting mechanism comes on top. If you do have a foreign bank account personally, as a Norwegian tax resident you report the balance at year end and the interest income. The tax return can handle foreign currency, and where you convert yourself, use Norges Bank's rates in accordance with Skatteetaten's guidance.
An ordinary foreign company and a CFC are two different things
An ordinary foreign company does not necessarily mean current Norwegian tax on the company's undistributed profit. Where the company is a CFC, Norwegian owners can be taxed currently – before any dividend has been paid. RF-1245 and RF-1246 were withdrawn after the 2022 income year. In 2026 the CFC has to have a Norwegian registration number and file a company return with a business specification. The participants also report their shares in their own tax returns. The deadline is 31 May.
What if the company is actually run from Norway?
A company registered abroad can become tax resident in Norway where effective management is exercised here. The company then enters the Norwegian tax system as a company taxable on worldwide income – with a Norwegian company return, not just shareholder reporting. A NUF and a permanent establishment are not the same either. A NUF is a Norwegian registration of a foreign enterprise. Whether the business has a permanent establishment, and so Norwegian tax liability, is decided separately – see A foreign company setting up in Norway
Intra-group payments can trigger extra reporting
Loans, interest, management fees, royalties, sales of goods and other transactions between related parties can be caught by the rules on controlled transactions. In 2026 there is as a starting point an exemption from the separate return where total controlled transactions are under NOK 10 million and balances at year end are under NOK 25 million, with some exceptions.
The duty to inform and TP documentation are not the same
Small groups are as a general rule exempt from full documentation requirements where, together with related parties, they have fewer than 250 employees and either sales revenue of at most NOK 400 million or a balance sheet total of at most NOK 350 million. Businesses subject to the documentation requirement have to be able to produce it within 45 days of a request. Prices between related parties still have to be at arm's length even where the group is below the documentation thresholds. The exemption covers the documentation, not the pricing. Country-by-country reporting, by contrast, applies only to very large groups, with consolidated income above NOK 6.5 billion. The old RF-1352 has been replaced, and reporting is now in XML format.
Tax-free does not mean «do not disclose»
The Tax Administration Act requires correct and complete information necessary for the tax assessment. Where facts are relevant to, say, the participation exemption, a CFC exception or credit relief, they have to be disclosed – even where the conclusion is that the income is tax-free. That is one of the most common misunderstandings with foreign companies: not mentioning something because it will not be taxed anyway.
Mistakes can bring both enforcement fines and additional tax
In 2026 the court fee is NOK 1,345. For the tax return the enforcement fine is 0.5 court fees per day – NOK 672.50 per day – with a maximum of 50 court fees, NOK 67,250. More on how the fine is stopped is in Enforcement fines from Skatteetaten Ordinary additional tax is normally 20% of the tax advantage, with higher rates for more serious conduct – see Additional tax and aggravated additional tax
Have you previously left out a foreign company?
Voluntary disclosure can then be available where the conditions are met. On a voluntary disclosure Skatteetaten can go up to ten years back without additional tax, but the ordinary tax and interest have to be paid. The conditions – in particular that the correction must come before the agency has started its own enquiries – are covered in Voluntary disclosure
A practical checklist
Establish each year: personal or corporate ownership? Wealth value? Dividends or a share sale? CFC? Effective management? A permanent establishment? Intra-group transactions? Private foreign accounts and loans? The most important thing is to start with who owns what. A Norwegian shareholder, a Norwegian holding company and a foreign subsidiary are three separate legal and tax entities, and they report separately. Greenleaf can check foreign shareholdings, wealth values, dividends and gains or losses, credit relief, CFC reporting and intra-group balances. For assessments of tax residence, EEA substance, tax treaties and larger transfer pricing structures, an international tax adviser should be brought in where needed.
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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.
More on holding companies, structure and cross-border
- A holding company – when does it pay off, and when does it not?
- The participation exemption – when is a company exempt from tax on dividends and share gains?
- Can I put a holding company above an AS I already own?
- Group contributions – can a profit in one company cover a loss in another?
- Mergers and demergers – when is a reorganisation worth the work?
- A holding company abroad – what do Norwegian tax rules require?
- Effective management – when does a foreign company become taxable in Norway?
- CFC rules (NOKUS) – when are Norwegian owners taxed before the money comes out?
- Genuinely established in the EEA – what does the substance test mean in practice?
- Exit tax – what happens to your shares when you leave Norway?
- A foreign company setting up in Norway – what has to be in place?
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