In Norway, tax residency is primarily determined by the number of days spent in Norway. Residents are taxed on their worldwide income and wealth, and this taxation continues after departure unless "tax emigration" is granted. This page is based on information from the Norwegian Tax Administration (Skatteetaten). It explains what these sources establish, what falls under French jurisdiction, and what should be verified with a Norwegian tax professional. Withholding tax information between the two countries is available on the page about... France-Norway tax treaty.
The number of days: 183 over twelve months, 270 over thirty-six
Skatteetaten defines tax residence by the length of stay. A person residing in Norway is considered a resident if they:
- more than 183 days over a twelve-month period: "You stay in Norway for more than 183 days over a 12-month period"; ;
- or more than 270 days over a period of thirty-six months.
Any day started counts as a day of stay, without any requirement for consecutive days or a specific reason for being there. Registration in the population register alone does not create tax residency. The page on arrival in Norway notes that one can stay on average approximately 90 days per year without becoming a resident; this average is a summary.
Start of residency: if the 183 days are exceeded in the first year, residency begins on the first day; if the days are spread over two years of income, it begins on January 1st of the second. These Norwegian tests are not those of the convention with France, which uses 183 days "in the tax year" for salaries. For France, residency falls under Article 4 B of the French General Tax Code (CGI): see the... three criteria for French tax residency.
Worldwide Resident Taxation
A tax resident is liable to pay tax on all their income and wealth, both in Norway and abroad, and must declare both: "liable to pay tax on all your income and wealth in both Norway and abroad." Double taxation is avoided through relief measures. A non-resident may be subject to limited taxation. The mechanics of the tax credit, from the French perspective, are explained on our page about...«elimination of double taxation.
Leaving Norway: Tax emigration must be granted
Leaving Norway does not terminate tax residency. The "From Norway" page of the Norwegian Tax Administration (Skatteetaten) states: "If you move abroad, you're still liable to pay tax to Norway on all your income and wealth." The "Global tax liability" page clarifies that worldwide tax liability remains after departure and before cessation of tax residency is granted. According to the "From Norway" page, a departure of six months or more must be notified to the tax authorities.
The conditions for tax emigration depend on the length of time spent in Norway:
- Less than ten years of living in Norway : long-term stay abroad, no more than 61 days in Norway during the year for which cessation of tax liability is claimed ("the year for which you claim cessation of tax liability"), and no access to accommodation in Norway for the person or their relatives.
- Ten years or more : the obligation ceases three years after installation abroad, under the same conditions.
Here too, any day started counts as a full day of stay. These conditions are read only once; they are checked in full text before departure.
Exit tax: unrealized capital gains, with a deduction of NOK 3,000,000
The Norwegian exit tax targets unrealized capital gains on shares, fund units, employment-linked options, partnership interests, and derivatives. For departures on or after March 20, 2024, "You get a basic deduction of NOK 3,000,000 in the calculated latent gain or loss." The page does not provide a rate, and therefore we do not include one.
Payment can be made immediately, in installments over twelve years, or deferred: "defer the payment of the entire tax liability for 12 years." Security is generally required, except in cases of a genuine risk of non-recovery within the EEA. Since October 7, 2024, 70% of the company's distributions have been used to repay the tax liability. The tax is updated annually, before April 30, and the tax authorities can assess the tax up to fifteen years after departure or transfer. The NOK 100,000 threshold applies to assets received through inheritance: beyond a net latent gain of NOK 100,000, the exit tax is levied on the entire gain ("net latent gain exceeding NOK 100,000, you must pay exit tax on the entire gain").
The Exit Tax page does not have an update date. It mentions changes effective January 1, 2025 (transfers by inheritance): this information should be verified. The French equivalent is the exit tax, discussed in Leaving France, exit tax and tax residence.
Rates: a standard tax of 22 % and a tiered tax scale
The Skatteetaten rate pages do not display a date, but a year selector places 2026 first. Subject to this year restriction:
- ordinary personal income tax is 22.0 % (18.5 % in Troms and Finnmark); ;
- the tiered tax (trinnskatt) does not apply to the first 226,100 NOK of personal income, then follows the scale below.
| Share of personal income | Trinnskatt rate |
|---|---|
| up to 226,100 NOK | 0% |
| from 226,100 to 318,300 NOK | 1.7% |
| from 318,300 to 725,050 NOK | 4.0% |
| from 725,050 to 980,100 NOK | 13.7% |
| from 980,100 to 1,467,200 NOK | 16.8% |
| over 1,467,200 NOK | 17.8% |
The National Insurance Scheme contribution is 7.6 % on wages (for individuals aged 17 to 69) and 10.8 % on other business income, with a lower limit of NOK 99,650. Non-resident taxpayers pay the full contribution directly to NAV, and living or working abroad can terminate membership. For information on social protection for French expatriates, see the conditions for joining the Caisse des Français de l'étranger (French Nationals Abroad Fund).
Wealth tax: two tiers, thresholds for single people
Subject to the same vintage requirement, the wealth tax includes:
- a municipal tax of 0.35 % above NOK 1,900,000; ;
- a state tax of 0.65 % from 1,900,000 to 21,500,000 NOK, then 0.75 % beyond.
These thresholds apply to a single person and are doubled for a couple. Value reductions decrease the taxable base for certain assets; this page does not allow for their calculation here. For the French real estate wealth tax, see Wealth tax for non-residents.
Dividends and capital gains: the shareholder model
Skatteetaten describes the shareholder model: "dividend and gain after deducting a risk-free return are taxable as ordinary income." The benchmark return (the risk-free return (from the text) is calculated on a yield basis, multiplied by a rate announced each January. Unused yield is carried forward and then lost upon sale. The page does not provide an effective rate, and we do not calculate one.
Income of 800,000 NOK and a fortune of 10 million: a numerical example (fictitious profile)
Profile. A single person, a year-round resident of Norway, has a personal income of NOK 800,000 in salary. They own taxable assets of NOK 10,000,000. They are considering leaving with NOK 5,000,000 in unrealized capital gains.
Strategy. The tiered scale is applied, along with employee contributions, wealth tax, and then the exit tax deduction.
Result. The trinnskatt is NOK 28,105.55: NOK 1,567.40 on the 1.7 % bracket, NOK 16,270 on the 4.0 % bracket, and NOK 10,268.15 on the 13.7 % bracket. The employee contribution of NOK 7.6 % amounts to NOK 60,800. The wealth tax is NOK 81,000: NOK 28,350 municipal (0.35 % of NOK 8,100,000) and NOK 52,650 state (0.65 % of NOK 8,100,000), before any depreciation. For the exit tax, the base after the NOK 3,000,000 deduction is NOK 2,000,000; Since the rate is not indicated on the page, no tax is calculated. The standard tax of 22 % is not calculated due to the lack of a taxable base. The profile and amounts are fictitious.
What this page does not cover
- Inheritance tax, assurance-vie and local accounts: none of the official Norwegian pages I read describe them.
- The rules for the stay of French nationals beyond 90 days: the document consulted is not dated.
- Contributions according to CLEISS (2024 vintage).
- The effective rate on dividends and discounts on the value of wealth.
What changes depending on your situation
- Your number of days in Norway, per period of twelve and thirty-six months.
- The time already spent in Norway (less or more than ten years), for tax emigration.
- The nature of your assets: shares, funds, partnership interests, real estate.
- Your marital status, which doubles the wealth tax thresholds.
A Norwegian rule must be interpreted in light of the facts of your case. No outcome is guaranteed, and its application is validated with a Norwegian professional.
Frequently asked questions
How many days do you need to spend in Norway to become a tax resident?
More than 183 days over a twelve-month period, or more than 270 days over a thirty-six-month period. Any day started counts.
Does leaving Norway end Norwegian taxation?
Not just by leaving. Global taxation continues until tax emigration is granted, including a maximum of 61 days in Norway during the year for which cessation of tax liability is requested.
Does Norway levy an exit tax?
Yes, on the unrealized capital gain of certain assets, with a deduction of NOK 3,000,000 for departures since March 20, 2024. Payment can be deferred for twelve years.
Take stock of your situation
Balmont Conseil, a firm based in Lyon for nearly 14 years, advises executives and families whose assets or business activities connect France and Norway. To discuss your situation, please schedule an appointment.
Alexis SagnierFinancial and real estate investment advisor, insurance broker, AMF certified
Founder of Balmont Conseil, Lyon (ORIAS 13003497)
Read also
- France-Norway tax treaty: the details
- Leaving France: exit tax, tax residence, procedures
- French tax residence: the 3 criteria (art. 4 B)
- Double taxation: tax credit and effective tax rate
- Wealth tax for non-residents: taxable assets and the €1.3 million threshold
- French Overseas Social Security Fund: Membership Conditions
Official sources
- Skatteetaten, «From Norway»: https://www.skatteetaten.no/en/person/to-from-norway/from/
- Skatteetaten, «Global tax liability»: https://www.skatteetaten.no/en/person/to-from-norway/from/tax-when-you-move-abroad/global-tax-liability/
- Skatteetaten, «Tax when you move to Norway»: https://www.skatteetaten.no/en/person/to-from-norway/to/moving/tax-to-norway/
- Skatteetaten, «Tax emigration»: https://www.skatteetaten.no/en/person/to-from-norway/from/tax-when-you-move-abroad/tax-emigration/
- Skatteetaten, «Exit tax»: https://www.skatteetaten.no/en/person/to-from-norway/from/tax-when-you-move-abroad/exit-tax/
- Skatteetaten, ordinary income tax rate: https://www.skatteetaten.no/en/rates/general-income/
- Skatteetaten, «Bracket tax»: https://www.skatteetaten.no/en/rates/bracket-tax/
- Skatteetaten, national insurance contribution: https://www.skatteetaten.no/en/rates/national-insurance-contributions/
- Skatteetaten, «Wealth tax»: https://www.skatteetaten.no/en/rates/wealth-tax/
- Skatteetaten, the shareholder model: https://www.skatteetaten.no/en/person/taxes/get-the-taxes-right/shares-and-securities/about-shares-and-securities/the-shareholder-model/
- Skatteetaten, national insurance and departure: https://www.skatteetaten.no/en/person/to-from-norway/from/tax-when-you-move-abroad/national-insurance-contributions/