Norwegian revised national budget for 2025

As expected, the government proposes, among other things, reduced electricity tax and the establishment of an agricultural account. It was further proposed to introduce a new sharing scheme for renewable energy adapted to business areas. However, several anticipated changes were notably missing in the revised national budget, and the following can therefore be mentioned:

• Voluntary disclosure (tax amnesty): The government has not proposed adopting the previously proposed tightening of voluntary disclosure rules, nor provided any timeline for when such changes might be implemented. See our previous newsletter about the proposal that the Government presented on 9 October 2024.

• The exemption method: The government has evaluated the exemption method in the revised national budget, particularly the three percent rule for taxing dividends under the exemption method but has decided not to make any changes at this time. This means the current three percent rule remains stable for companies using the exemption method.

• The shareholder model: The government has further evaluated the risk-free return interest rate in the shareholder model and has concluded that no changes are needed at present. The current risk-free return interest rate in the shareholder model will therefore remain unchanged.

• Taxation of NOKUS companies: The government has conducted a brief evaluation of the current tax scheme for NOKUS companies (Norwegian-controlled foreign companies). They plan to examine more closely the interaction between the NOKUS rules and supplementary tax, as well as the exception from the NOKUS rules for companies in countries with tax treaties with Norway.