Carina Raa
Senior Lawyer
Oslo
Newsletter
The final Norwegian National Budget for 2025
by Carina Raa and Cecilie Amdahl
Published:
On 1 December 2024, the Norwegian Government and the political party SV reached a settlement for the Norwegian National Budget for 2025, with some amendments made on 9 December 2024 just before the parliamentary resolution. A few amendments have been made to the exit tax, but other than that, no major adjustments have been made to the proposed National Budget for 2025 regarding direct and indirect taxes.
The amendments to the exit tax, as set out in the proposed National Budget for 2025, are all in all upheld. Therefore, all individuals emigrating from Norway on or after 20 March 2024 must pay exit tax no later than 12 years after emigration is upheld, regardless of realization of shares. No exceptions for persons only living in Norway for a limited period of time, and no adjustments to the calculated exit tax if the value of the underlying shares is reduced or lost after emigration.
The exit tax can be paid at the end of the 12-year period, with the addition of accrued interest. However, if any dividend distribution is received during the 12-year period, 70% of the dividend distribution shall be paid as instalments on the exit tax. Following an amendment made on 9 December 2024, the payment of exit tax in case of dividend distribution shall not lead to total tax (exit tax and tax on dividend distribution) exceeding 100% of the dividend distribution amount – which could have been the situation with the initial proposal from October. The "exit dividend tax" is effective from 7 October 2024.
