jurisdiction
Updated on December 2023
Investment vehicle
- Norwegian limited company (Aksjeselskap)
- Norwegian internal partnership (Indre selskap)
1. Form
Norwegian limited company (Aksjeselskap)
- Corporate: Private limited company
Norwegian internal partnership (Indre selskap)
- Contractual partnership without legal personality
- Legal title to assets held by general partner
2. Tax Treatment
Norwegian limited company (Aksjeselskap)
- Opaque. Ordinary income taxed at 22% on the hands of the company.
- Dividends and capital gains on shares subject to participation exemption for Norwegian corporate investors.
- WHT of 25% applies to dividends, but the rate may be reduced under an applicable double tax treaty. Exemption may apply where the recipient is a corporate entity genuinely established within the EEA.
Norwegian internal partnership (Indre selskap)
- Transparent
- Income is calculated on company level and attributed to the participants based on ownership interest.
3. Transfer Tax
Norwegian limited company (Aksjeselskap)
- Real estate transfer tax of 2.5% on registration of deed (calculated on the basis of the consideration (e.g. purchase price))
- No other transfer taxes or stamp duties
Norwegian internal partnership (Indre selskap)
- Real estate transfer tax of 2.5% on registration of deed (calculated on the basis of the consideration (e.g. purchase price))
- No other transfer taxes or stamp duties
4. Listable
Norwegian limited company (Aksjeselskap)
- Yes (but would be highly unusual)
Norwegian internal partnership (Indre selskap)
- No
5. Open- or closed-ended
Norwegian limited company (Aksjeselskap)
- Open- or closed-ended
Norwegian internal partnership (Indre selskap)
- Open- or closed-ended
6. Regulatory Supervision
Norwegian limited company (Aksjeselskap)
- AIFM regulated by the Norwegian Financial Supervisory Authority (Finanstilsynet)
Norwegian internal partnership (Indre selskap)
- AIFM regulated by the Norwegian Financial Supervisory Authority (Finanstilsynet)
7. Investor Restrictions
Norwegian limited company (Aksjeselskap)
- No
Norwegian internal partnership (Indre selskap)
- No
8. Best Feature
Norwegian limited company (Aksjeselskap)
- Flexible
Norwegian internal partnership (Indre selskap)
- Flexible and high resemblance to limited partnership
- Tax transparency
9. Worst Feature
Norwegian limited company (Aksjeselskap)
- Withholding tax on dividends
Norwegian internal partnership (Indre selskap)
- Norwegian foundations may not invest
- Nordic investors are unfamiliar with the legal construction
- Foreign participants/investors risk creating a Norwegian taxable presence (PE)
10. Best Used For
Norwegian limited company (Aksjeselskap)
- All strategies
Norwegian internal partnership (Indre selskap)
- All strategies
