The Norwegian Ministry of Finance proposes to introduce tax liability for foreign companies and employees who want to have income from aquaculture (sea farming) on the Norwegian Continental Shelf. It is also proposed to introduce tax liability for foreign workers who have income in connection with mineral activities, exploitation of renewable energy resources (offshore wind) and carbon management on the continental shelf. This follows up on the tax liability for foreign companies' operating income from these activities, which was introduced in the national budget for 2024.
“The rise of new industries means that greater activity is expected on the Norwegian continental shelf in the future. We want to ensure that the community gets a rightful share of foreign companies' value creation in Norwegian areas, and therefore make some necessary tax measures to ensure national control,” says Finance Minister Trygve Slagsvold Vedum (Sp).
For the activities covered by the proposal, there is currently no authority in the tax act to tax foreign companies and persons who operate or participate in activities on the continental shelf, while income from companies and persons who are already resident or domiciled here are liable to tax.
“We want to do something about this. We want to ensure that the community gets its rightful share of the values created from the exploitation of our common natural resources. The proposal also facilitates equal treatment of Norwegian and foreign companies and employees,” says Finance Minister Trygve Slagsvold Vedum (Sp).
The proposal that is being put forward now, together with the tax liability for mineral activities etc. which is introduced from 2024, will ensure Norway the right to tax income that comes from our common natural resources.
For foreign companies and persons covered by the proposals, the Tax Act's rules on tax on ordinary income (22 percent tax rate) will apply.
It is proposed that the changes should take effect from and including the income year 2025. The deadline for comments on the consultation memorandum is June 17, 2024.
