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11 October 2018

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Norway National Budget 2019 Presented

On 8 October 2018, the Norwegian government presented the National Budget for 2019 in parliament. The main tax-related measures include:

  • A reduction in the corporate tax rate from 23% to 22%;
  • An increase in the special petroleum income tax from 55% to 56%, along with a reduction in the rate of uplift (investment-based extra depreciation) from 5.3% to 5.2% per year for four years;
  • An extension of the 25% of EBITDA net interest deduction cap to both related and unrelated debt (currently just applies to related) and an increase in the de minimis safe harbor from NOK 5 million to NOK 25 million, along with the introduction of an escape clause that will allow a full deduction of interest paid to unrelated parties if the equity ratio of the company equals or exceeds the equity ratio in the group’s consolidated financial statements;
  • The amendment of the corporate tax residency rules to provide that a company will be considered tax resident in Norway, and subject to tax on its worldwide income, if it is incorporated or has its place of effective management in Norway unless the provisions of an applicable tax treaty provide otherwise; and
  • A reduction in the individual income tax rate from 23% to 22% and an adjustment of the bracket tax as follows:
    • up to NOK 174,500 – 0%
    • over NOK 174,500 up to 245,650 - 1.9%
    • over NOK 245,650 up to 617,500 - 4.2%
    • over NOK 617,500 up to 993,300 - 13.2%
    • over NOK 993,300 - 16.2%

The Budget for 2019 also includes certain measures includes as part of the Revised Budget for 2018, subject to EFTA Surveillance Authority approval, including:

  • The introduction of a tax regime for temporary foreign employees working in Norway that includes a flat 25% withholding tax on gross income with no deductions; and
  • An extension of the VAT exemption for electronic newspapers to e-books and e-magazines from 1 July 2019.

Aside from the VAT exemption for e-publications, the measures are to apply from 1 January 2019.

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