Updated on January 2026

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. Pros

Norwegian limited company (Aksjeselskap)

  • Flexible 

Norwegian internal partnership (Indre selskap)

  • Flexible and high resemblance to limited partnership  
  • Tax transparency  

9. Cons

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