On 15 October 2025, the government presented its proposed state budget for 2026. Here are the most important proposed changes in corporate tax for Norwegian companies.
No change in the corporate tax rate
The proposal is that the general corporate tax rate will remain at 22%. The government emphasises predictability and stable framework conditions for Norwegian businesses. This means that companies will continue to be taxed at the same nominal rate as in 2025, without adjustments for inflation or special deductions.
Although the rate remains unchanged, several adjustments to the basis for taxation are proposed, particularly aimed at international operations and structuring.
Change in tax rules for mutual funds and fund accounts
The government is proposing significant changes to how mutual funds and fund accounts will be taxed from 2026. If approved, this will be the most comprehensive reorganisation of fund taxation in many years and will affect both private investors and companies that invest in funds. The reason for the proposal is to prevent funds from moving out of Norway, and to ensure more neutral taxation between forms of investment and alignment with EEA law.
Interest income and income from financial instruments will be exempt from taxation in the fund, with taxation being levied on the unit holder. All equity income in the fund, including dividends and gains, will be exempt from ordinary tax in the fund, but standard taxation of dividends received will be introduced at 1 % of gross income, less all management costs.
The scope is narrowed to UCITS funds, Norwegian national funds and corresponding EEA funds, with further criteria in regulations. Funds that lose their exemption will have their input value adjusted upwards to market value as of 31 December 2025.
Companies' investments in fund accounts will follow the exemption method on normal terms, and the template will be adjusted so that non-securities are included in the interest portion. This closes the possibility of companies achieving more favourable taxation through fund accounts than through direct investment.
The proposal entails a revenue loss of NOK 570 million.
Prohibition of tax-free mergers between limited companies and housing cooperatives
It is proposed to close the so-called multi-stage model, or “borettslag model”, which has been used in the real estate industry to achieve tax exemption on reorganization. The model describes a transaction structure where a property is transferred from a limited company to a housing cooperative without the transfer triggering capital gains tax. The model has made it possible to sell housing cooperative shares tax-free from the housing cooperative's owner to the home buyers, provided that the value of the property at the time of implementation of the model corresponds to the sales price to the buyers.
The proposed prohibition will mean that such a merger between a limited liability company and a housing cooperative can no longer be implemented without taxation. The purpose is to prevent companies from avoiding capital gains tax when restructuring housing projects, which the government believes erodes the tax base and weakens confidence in the tax system.
The change is proposed to come into force from 15 October 2025, with transitional rules until 1 April 2026 for projects that have already received a building permit or commissioning permit. Exceptions have also been made in cases where one or more housing units have already been pre-sold under the Residential Property Listing Act.
This measure is estimated to increase corporate tax revenue by approximately NOK 900 million annually.
Changes for specific industries
In addition, some changes have been proposed for specific industries, including:
- Product tax on fish: The product tax to the National Insurance Scheme for the fishing industry will be reduced from 2 % to 1.6 % in 2026. The reduction is partly due to the fact that the proportion of pensionable income in the industry has fallen to 32.3% due to efficiency improvements.
- Agricultural account: The limit for recognizing income from agricultural accounts will be reduced from 85% to 80% from 1 January 2026. This will result in an accrued revenue loss of approximately NOK 190 million in 2026.
Base rate tax for power
The resource rent tax for hydropower and wind power will be adapted to the new time period in the spot market (from hourly to quarterly from 30 September 2025). The change is not expected to result in revenue changes.
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Note also important proposed adjustments in the Supplementary Tax Act for groups with narrow income above EUR 750 million, as well as for financial institutions with operations abroad.
Also read: International tax in the 2026 state budget
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The proposals presented in the state budget for 2026 are not yet finalized.
The budget marks the start of the negotiations in the Parliament, where both tax and duty changes are traditionally subject to extensive political discussions and adjustments.
