A foreign company setting up in Norway – what has to be in place?

Five questions have to be kept apart, and the answers can differ: does the company have to register in Norway, is the business taxable here, are the sales subject to Norwegian VAT, does the company have Norwegian employer obligations, and do assignments and workers have to be reported separately? One employee can trigger registration and payroll reporting long before the company has a permanent establishment.

The obligations come before the office

A foreign company can start acquiring Norwegian obligations long before it opens a formal office in Norway. One employee can trigger registration and payroll reporting. A Norwegian construction project can trigger VAT. An office or an agent can create a permanent establishment and Norwegian corporation tax. And a Norwegian organisation number does not in itself mean the company is taxable. The first thing to do is therefore to separate five questions: does the company have to register in Norway, is the business taxable here, are the sales subject to Norwegian VAT, does the company have Norwegian employer obligations, and do assignments and workers have to be reported separately?

A Norwegian subsidiary or a NUF?

A Norwegian subsidiary. The foreign parent forms a Norwegian AS. The share capital has to be at least NOK 30,000. As a Norwegian company the AS is as a starting point taxable in Norway on worldwide income and follows ordinary Norwegian rules on tax, accounting, VAT and employer obligations. Corporation tax is 22% in 2026. A NUF. The alternative is to keep the existing foreign company and register it as a Norwegian-registered foreign enterprise. A NUF is not a new company. The foreign enterprise remains the legal person and is responsible for the business in Norway, so a NUF does not give the same separate limitation of liability as a Norwegian subsidiary.

A NUF and a permanent establishment are not the same

A NUF is a registration. A permanent establishment is a tax assessment. A foreign enterprise can be registered as a NUF without necessarily having a permanent establishment under the relevant tax treaty. Foreign companies carrying on independent business activity in Norway, or simply having employees working here, can need a Norwegian organisation number – even where the treaty gives no permanent establishment. Registration and income tax have to be assessed separately.

When does Norwegian corporation tax arise?

A foreign company can have limited tax liability under Norwegian domestic law for business carried on here or managed from here. Where the company is resident in a country Norway has a tax treaty with, ordinary business income normally requires a permanent establishment before Norway can tax the business profit. Typical permanent establishments are an office, a factory, a workshop, a branch and a place of management. Where there is a permanent establishment, the profit attributable to the Norwegian activity is taxed – not automatically the company's whole worldwide profit.

A construction project can become a permanent establishment after a time limit

Building, construction, installation and assembly projects often have their own time limits. The OECD model normally uses more than 12 months, but Norwegian tax treaties vary. A foreign contractor should therefore not use «we are here for under 12 months, so we are safe» as a general rule. The specific treaty has to be read.

A person in Norway can also create a permanent establishment

A dependent person can under a treaty create a permanent establishment where they have a sufficient role in concluding contracts. In the Dell judgment, Rt. 2011 p. 1581, the Irish company was held not to have a permanent establishment on the wording of the treaty then in force. Later international rules, including the MLI, have opened for broader agent rules in some treaties. The specific treaty therefore has to be read – the judgment is not a general exemption.

VAT follows different rules from corporation tax

A foreign company can be not liable to income tax and at the same time required to register for VAT in Norway. The ordinary registration threshold is NOK 50,000 of taxable turnover and withdrawals in any twelve-month period – see VAT registration. For remotely deliverable services to a Norwegian business customer it is often the Norwegian buyer who accounts for the VAT under the reverse charge rules. But that does not apply to every service. Building and construction services carried out on Norwegian real property, by contrast, can be ordinary Norwegian taxable supplies, and the foreign business then becomes liable to register in the ordinary way once turnover passes the threshold.

When is a Norwegian VAT representative needed?

Foreign businesses without a place of business or residence in Norway must as a starting point register through a Norwegian VAT representative. Skatteetaten at the same time maintains a list of EEA states, plus the United Kingdom, from which businesses can register directly without a Norwegian VAT representative. Check the current country list. For qualifying goods, the VOEC scheme applies to goods with a value up to NOK 3,000 per item – not per parcel. The scheme can also be used for qualifying remotely deliverable services to private recipients. VOEC is a simplified reporting scheme, not an exemption from Norwegian VAT once the duty to register has arisen.

Employees can create Norwegian obligations without a permanent establishment

A foreign company with employees in Norway may have to obtain a Norwegian organisation number, report the employment relationships, obtain tax cards, make advance tax deductions where required, and file the a-melding – even where the company has no permanent establishment. The a-melding is normally filed on the 5th of the month after the month of payment, or the next working day if the 5th falls on a weekend or a public holiday. The employment relationship is reported every month for as long as it lasts. See also Missed an a-melding

The tax withholding account is gone from 2026

From 1 January 2026 employers no longer place advance tax deductions in a separate withholding account. The deduction is instead paid directly to Skatteetaten, by the first working day after the salary payment. This is one of the changes foreign employers most often miss, because it arrived in the middle of a financial year – see Advance tax deductions not paid

Employer's contributions also depend on social security membership

Someone working in Norway does not automatically mean Norwegian employer's national insurance contributions are due. EEA rules, A1 documentation and social security agreements can mean the worker still belongs to their home country's system – see Employees abroad and foreign employees in Norway. Where Norwegian contributions do apply, the ordinary rates in 2026 run from 0 to 14.1%. A foreign enterprise with no registered Norwegian business address uses zone I at 14.1% as a starting point.

183 days is not a universal tax-free period

An employee can become taxable before 183 days where, among other things, the employer has a permanent establishment in Norway, the cost is charged to a Norwegian permanent establishment, the worker is hired out to a Norwegian business, or the economic employer rules give Norway the taxing right. 183 days is therefore part of the test – not the whole test.

Assignments and foreign workers have their own reporting

Where a client gives an assignment to a foreign contractor to be carried out in Norway or on the Norwegian continental shelf, reporting to the Register of Assignments and Employment Relationships (OAR) applies. The client reports the assignment, and the foreign contractor reports the workers on it. The deadline rules have changed in recent years, and older guides – and some newer ones – give different deadlines. Check the current deadline with Skatteetaten before the first filing rather than relying on a figure from an article. The exemptions are stable: assignments with agreed consideration under NOK 20,000, cabotage assignments, assignments given by private individuals and assignments carried out on Svalbard are not reportable. The reporting duty covers the main client, the direct client and contractors up to two levels down the contract chain.

A NUF can have Norwegian accounting and audit obligations

A NUF carrying on business in Norway and taxable here under Norwegian domestic law can be required to keep accounts and file them with the Register of Company Accounts. A NUF registered in the Register of Business Enterprises without an accounting obligation has to deal with that separately with the Register of Company Accounts. The audit threshold is no longer NOK 5 million. For NUFs subject to accounting requirements, the 2026 rules refer to thresholds of NOK 7 million in operating income, NOK 27 million in balance sheet total and 10 full-time equivalents or more. Passing the thresholds can trigger an audit requirement for the following financial year.

Intra-group prices have to survive the arm's length principle

Where the foreign enterprise has a Norwegian branch, the profit belonging to Norway has to be allocated under the tax rules and the treaty. Where the group instead has a Norwegian subsidiary, goods, loans, management fees, royalties and other transactions between parent and subsidiary have to be priced at arm's length. What has to be reported is set out in Do you own a foreign company? How to report it correctly

Dividends back to the parent meet withholding tax

The Norwegian general rule is 25% withholding tax on dividends to foreign shareholders. A tax treaty can reduce the rate. A qualifying EEA company that is genuinely established and carries on genuine economic activity can be entitled to 0% under the participation exemption.

Four typical set-ups

1. The company only sells into Norway from abroad. Norwegian corporation tax will normally require a sufficient Norwegian connection, often a permanent establishment under a treaty. VAT can still arise. 2. The company sends employees to Norway. A Norwegian organisation number, OAR reporting, tax cards, the a-melding and advance deductions can all become relevant even where there is no permanent establishment. The employee's personal tax liability and the employer's corporation tax are assessed separately. 3. The company gets a permanent office or branch in Norway. NUF registration is often natural, and the likelihood of a permanent establishment rises. 4. The group sets up Norway AS. The group gets a separate Norwegian legal entity with its own agreements, accounts, tax and risk. That is often the tidiest solution where the Norwegian business will be permanent and have its own employees, larger contracts or local management.

Start with the activity – not the company form

The most common mistake is to start with «should we have a NUF or an AS?» before knowing what the business will actually do in Norway. Start instead with: are we only selling from abroad? Will employees work physically in Norway? Will we have a Norwegian office or warehouse? Will people in Norway negotiate or conclude contracts? Will we do building and construction work? Are we selling B2B or B2C? Are the services remotely deliverable or tied to a place? How long will the activity last? Once that is mapped, you can take registration → tax → VAT → payroll → OAR → accounting in the right order. Greenleaf can help foreign companies with Norwegian registration, payroll and the a-melding, advance deductions, employer's contributions, VAT, OAR reporting, branch accounts, the year-end close and continuing Norwegian tax and duty reporting. Assessments of permanent establishment under a treaty, hired labour and economic employer questions, international transfer pricing and complicated cross-border structures should be quality-assured by a tax lawyer or another international specialist where needed. What a NUF registration actually is – and is not – is set out in NUF – what is it, and when does it make sense?

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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