A loan from your own AS – why is a «loan» taxed as a dividend?
The Taxation Act treats a loan from a limited company to a personal shareholder as a dividend, however genuine the loan is in private law. You get the tax now and still owe the company the money. The exception is small credits under NOK 100,000 dealt with within 60 days – and the threshold is measured against the total balance, not against each withdrawal.
A lawful loan and a tax-free loan are two different questions
The Companies Act asks whether the company is allowed to give the credit. The Taxation Act asks how the shareholder is taxed. A loan can therefore be entirely lawful under section 8-7 of the Companies Act and at the same time be taxable as a dividend. Your auditor or lawyer saying the loan is fine as a matter of company law does not answer the tax question. As a general rule section 8-7 requires the loan to be within the company's distributable headroom and to have adequate security. The board also has to respect the requirement for adequate equity and liquidity.
The tax can arrive even though you still owe the money
If you borrow NOK 300,000 from your wholly owned AS and no exception applies, the loan can be taxed as a dividend. At the 2026 rate of 37.84% the tax before any shielding is NOK 113,520. But you still owe the company NOK 300,000. The dividend tax does not cancel the loan – it comes on top of it.
Under NOK 100,000 and repaid within 60 days
There is an important exception for smaller, short-term credit. The total credit has to be under NOK 100,000, and the whole relevant amount has to be dealt with within 60 days under the rules. Once the total balance reaches NOK 100,000 or more, the small-credit exception falls away. Several small withdrawals are assessed against the total balance – you cannot get around the threshold with three withdrawals of NOK 50,000. Private purchases on a company card create this kind of credit too. That is the most common way the threshold is passed without anyone thinking of it as a loan.
Ordinary customer credit has its own exception
An ordinary trade receivable arising in the company's normal business can fall outside the shareholder loan rules if it is dealt with within the specific deadlines. This is not a general route to financing private consumption through your own company. The exception assumes the credit is the same as the company gives other customers.
What happens if you repay the loan?
Where the loan has already been taxed as a dividend, you do not get the original tax refunded when you repay. A cash repayment is instead treated as new tax-paid-in capital and increases the tax base and shielding basis on the shares. The value does come back to you, but later and in a different form. Where a later lawful dividend is set off against the previously taxed loan, the same amount is normally not taxed twice.
New withdrawals mean a new assessment
New drawings on the intercompany account can trigger fresh tax. So it is not enough to look at the balance on 31 December. The movements through the year can be decisive, and an account that is nil at the year end can still have triggered taxable withdrawals in March and August.
What if you lend money to the company?
Then the position is entirely different. If you personally lend NOK 1,000,000 to your own AS, the company can normally repay the principal without it becoming salary or a dividend. The interest income is first taxed ordinarily at 22%, but section 5-22 of the Taxation Act has its own extra tax on high interest on loans from a personal taxpayer to a company. The shielding rate for that rule is set every two months. For September and October 2026 it is 3.8%. The calculation is monthly and more complicated than «everything above 3.8% is taxed extra» – the rate for November and December 2026 had not been set as at September.
Losses on a loan to your own company
If the company goes bankrupt, a personal shareholder as a general rule gets no deduction for a loss on an ordinary loan to their own company merely because they own it or work there. That contrasts sharply with a deductible loss on personally owned shares, where the deduction value in 2026 is 37.84%. So how you finance your own company – equity or debt – has consequences you only see if things go wrong. See also Directors' liability and personal liability
Reporting
Taxable shareholder loans have to be reported through the shareholder register statement. Repayment also has to be reported, because it affects tax-paid-in capital and the tax base. From June 2026 filing goes through an end-user system. Greenleaf can reconcile the balances, calculate taxable shareholder loans, handle the reporting and calculate the interest taxation where the owner has lent money to the company.
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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.
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