Exit tax when leaving Norway

Exit tax when leaving Norway

What is Exit Skatt in Norway?

Exit Skatt (utflyttingsskatt) is a tax paid by some people when leaving Norway, designed to close a tax loophole that allowed Norwegian tax residents to move out of the Land of the Fjords without paying the tax due.

It applies when we cease to be Norwegian tax residents and hold capital assets such as shares, units in investment funds or other financial instruments. This tax covers capital gains that would have been taxed if we had sold them before leaving Norway. The purpose of this tax is to prevent tax avoidance by people leaving Norway.

When does Exit skatt apply?

Exit Skatt applies when the conditions for ending tax residency in Norway are met – that is, when our unlimited tax liability “moves” to another country – under Norwegian rules or tax treaties with other countries. This means that if we move our place of residence abroad and therefore lose our tax resident status in Norway, we may be required to pay this tax on gains from our capital assets.

The Exit Skatt tax applies only to certain financial instruments and does not cover all assets. Taxation applies to capital gains from:

1. Shares, units and ownership certificates in Norwegian companies
2. Aksjesparekonto
3. Interests in Norwegian partnerships
4. Shares and interests in foreign companies that are equivalent to Norwegian capital structures
5. Rights to buy shares, options and other financial instruments linked to the assets listed above
6. Some capital insurance policies (kapitalforsikring)

Does the tax on leaving Norway apply to me?

To find the answer to this question, first answer a few questions for yourself:

• Do you own shares, units in investment funds or other financial instruments?
• Are you planning to leave Norway for more than 6 months, which usually means you will cease to be tax resident in the country?
• Would your capital assets be worth more at the time of moving than when you bought them (i.e. have they increased in value)?
• If they have increased in value, does the value of your total potential capital gain (shares etc.) exceed 500 000 NOK?
• Are you transferring your assets to a person who lives outside Norway?

If you answered “yes” to most of these questions, there is a high probability that you will be required to pay Exit Skatt.

On the other hand, if:

• You do not own any taxable financial assets – you have not bought shares etc.,
• Your assets have not increased in value – there has been no gain,
• The value of your capital gain does not exceed 500 000 NOK,

then Exit Skatt does not apply to you and you will not have to pay this tax when leaving Norway.

How much tax will I pay?

Exit Skatt is calculated on the basis of the value of your capital assets on the day before you lose tax residency in Norway. For example, if you move to Poland and leave Norway permanently on 10 June, you automatically lose Norwegian tax residency, so the value of the assets on 9 June is taken into account.

The tax rate for capital gains (e.g. share sales, dividends) in 2025 is 37,84% after applying the tax multiplier of 1,72.

Examples:

1. You have shares that have increased in value
   • Let’s assume you bought shares a few years ago for 4 000 000 NOK, and their value at the time of leaving is 8 000 000 NOK.
   • Your capital gain is 4 000 000 NOK (market value minus purchase price).
   • This amount is multiplied by 1,72, giving 6 880 000 NOK.
   • Tax is charged at 22% on this amount:
     6 880 000 NOK x 22% = 1 513 600 NOK.
2. You have units in an investment fund (shares and bonds)
   • Let’s assume you hold units in an investment fund worth 3 500 000 NOK at the time of leaving. Depending on the fund structure, Exit Skatt will be charged at different rates:
     • Equity fund (more than 80% shares)
       • The entire gain is treated as a capital gain from shares, so it is taxed at 37,84%.
       • If the value of your fund units increased from 2 000 000 NOK to 6 000 000 NOK, the gain is 4 000 000 NOK.
       • Conversion using the factor 1,72: 4 000 000 NOK x 1,72 = 6 880 000 NOK.
       • Tax: 6 880 000 NOK x 22% = 1 513 600 NOK.
     • Bond fund (more than 80% bonds)
       • The entire gain is treated as interest income and is taxed at 22%.
       • If the fund value rises from 2 000 000 NOK to 3 000 000 NOK, the tax is:
         1 000 000 NOK x 22% = 220 000 NOK.
     • Mixed fund (20-80% shares)
       • The gain is split proportionally between the equity and bond portions.
       • If your fund has 60% shares and 40% bonds, and the gain is 1 000 000 NOK, then:
         • 600 000 NOK is treated as share income (37,84%)
         • 400 000 NOK is treated as interest income (22%)
       • Tax on the equity portion: 600 000 NOK x 1,72 x 22% = 226 460 NOK
       • Tax on the bond portion: 400 000 NOK x 22% = 88 000 NOK
       • Total tax: 226 460 NOK + 88 000 NOK = 314 460 NOK

NOTE! In the case of Exit Skatt, loss relief does not apply, which means that you will not receive a tax refund even if you make a loss on shares! The loss will only be taken into account for any future settlement if you decide to sell the assets after moving.

How can I avoid this tax?

If you already know from the previous points that exit skatt applies to you, one way to avoid it is to return to Norway before selling the assets. In that case, the tax liability is cancelled.

It is also possible to use a mechanism that defers payment of the tax until the assets are actually sold, provided certain conditions are met, for example moving to an EU/EEA country that has an agreement with Norway on the exchange of tax information.

Another option that allows you to temporarily avoid paying the tax is to defer payment or spread it over instalments for a period of 7 years. However, the tax must initially be paid in an amount of at least one seventh of the originally assessed tax. Deferred payment applies to withdrawals of all types of assets and liabilities.

Will I pay this tax if I never return to Norway?

The answer to this question depends on the date you left Norway.

1. If you left after 29 November 2022:

• The tax liability is indefinite.
• This means that even if you never return to Norway, when you sell assets subject to Exit Skatt you will still have to pay tax on their value on the day before you left.
• This tax remains in force regardless of where you live and how long you stay outside Norway.

2. If you left before 29 November 2022:

• The tax liability expires after five years.
• This means that if you have not sold your assets within five years of leaving, Exit Skatt will no longer apply, and any tax on gains will be charged under the rules of the country where you currently live.
• However, if the sale took place within five years, you still have to pay Exit Skatt in Norway.

In short:

• Leaving after 29 November 2022 = tax applies indefinitely
• Leaving before 29 November 2022 = tax applies for 5 years, then expires.

Does the tax apply to Polish citizens?

Yes, the exit tax applies to all people who lose tax resident status in Norway, regardless of nationality. Poles working and investing in Norway who decide to return to Poland or move to another country may be subject to this tax obligation if they hold assets covered by Exit Skatt.

This is because even with Polish citizenship, we can be tax resident in Norway. This happens due to the rules in force in both countries. If you want to check where your tax residency is, you can do it free of charge in Polish here (click).

What changes to Exit Skatt were introduced in 2025?

As part of the State Budget for 2025, the Norwegian government changed several Exit Skatt rules:

1. Higher exemption threshold
   • From 2025, the new exemption threshold is 3 million NOK.
   • This means that if net gains on leaving amount to, for example, 3.5 million NOK, tax will be charged only on 500 000 NOK. If our gain is less than 3 million NOK, we pay nothing.
2. Longer instalment period
   • It is now possible to spread payment of the tax over 12 years. These are more favourable conditions for the taxpayer, who has more time to pay the tax than under the previous rules.
3. Changes to inheritance rules
   • If a person covered by Exit Skatt dies, the tax will not be collected if the heirs are tax residents of Norway.
   • If the heirs live abroad, they may use the option of deferring payment.
   • If they return to Norway within 12 years, the tax will be cancelled in full.
4. Possibility of using shares as tax security
   • Taxpayers will be able to pledge shares as security for tax liabilities.
   • If the value of the shares falls, the security will still be sufficient, and the taxpayer does not have to repay the tax immediately.
5. Changes to dividend rules
   • Previously, some people moved abroad, paid dividends and then returned to Norway, avoiding tax on the increase in share value. The new rules have closed this loophole – from 2025, Exit Skatt must be paid at the time the dividend is paid out. The new rule is intended to apply to all new cases of departure and transfer of assets.

Can the tax be paid in instalments?

Yes, in certain cases it is possible to defer payment of Exit Skatt. People subject to Exit Skatt may apply for deferred payment until they actually realise the gain (e.g. sell shares). To use this option, one of the following conditions must be met:

• Tax security – the taxpayer must provide a financial guarantee (e.g. in the form of a charge over assets) to ensure that the tax will be paid in the future.
• Moving to an EU/EEA country – if the destination country has an agreement on exchange of tax information and assistance in debt recovery with Norway (e.g. Poland), it is possible to obtain deferral without having to provide security.
• Moving to Svalbard – if a person moves to Svalbard, they may also benefit from deferral without the need for a charge.

If I do not meet the criteria, are there other taxes I need to worry about when leaving?

Yes, even if in a given year you leave Norway and cease to be a tax resident, you must remember that you are obliged to settle all Norwegian income here. In most cases the return is automatic, but often corrections to data entered by the tax office are necessary, or you may be able to add tax deductions to which you are entitled.

Efremtid.no can help you submit, amend or add information in your annual tax return, whether it is tax return in Poland or tax return in Norway.

Does Exit Tax in Norway apply to property sales?

No, Exit Skatt does not cover property. This tax applies to capital gains from shares, units in investment funds and other financial instruments, but does not apply to the sale of property in Norway.

However, leaving Norway may affect how income from property sales is taxed:

1. Sale of property before leaving
   • If you sell the property before leaving, the standard Norwegian tax rules apply.
   • You can avoid tax if you have owned the property for at least 12 months before the sale and lived in it for at least 12 months during the last 24 months. For holiday homes, the exemption applies if you have used the property for at least 5 years during the last 8 years and have owned it for at least 5 years before the sale.
2. Sale of property after leaving
   • If you sell the property after leaving, you may still be subject to Norwegian tax if Norway still considers you tax resident (which can be appealed) or it is subject to tax always (apart from general tax exemptions, as in the previous point), if the property is located in Norway.
   • Some double taxation treaties between Norway and other countries may affect where tax on the sale must be paid – in most cases, however, we pay tax in the country where the property is located and, if the tax is higher, we pay the difference in the country of tax residence.
3. Renting out property after leaving
   • If you leave Norway but keep the property and rent it out, rental income may still be taxable in Norway

Does Exit Tax in Norway apply to cryptocurrencies?

Cryptocurrencies are treated in Norway as digital assets, not securities. This means that owning them does not create an obligation to pay Exit Skatt when tax residency is lost.

However, selling cryptocurrencies after leaving may still be taxable in the country you move to, and may also affect your tax obligations in Norway depending on the tax rules of the country concerned.

If you want to ask about taxes, benefits or other official matters – please contact us: +47 21 38 38 21.

We answer Mon-Fri from 9:00 – 21:00 and will be happy to help!

Author of the article: Marcin – marcin@efirma.no