The biggest surprise of the budget settlement was the introduction of immediate changes to the exit tax rules, which previously stated that tax on latent gains derived from shares and certain other securities would expire if they were not actually realized within 5 years following the taxpayer becoming a resident abroad. The budget settlement thus means that the tax on latent gains will not expire at all, and that the taxpayer will have to pay the latent tax when the gains are realized, regardless of the number of years that have passed since the taxpayer moved abroad.
The changes to the exit tax rules will have extensive effects on both taxpayers and the tax administration, as annual confirmations of non-realization of gains will have to be submitted every year until it is either realized or the taxpayer moves back to Norway. It will also complicate matters with international mobility as the rules will also affect both Norwegian and foreign businesses with cross-border activities and employees who move between Norway and other jurisdictions. Furthermore, the exit tax rules are expanded to affect transfers to family members who reside abroad, whereas the previous rules only affected transfers to a spouse abroad.