Popular investment vehicles in Norway

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
Portrait ofJohan-Svedberg
Johan Svedberg
Partner
Oslo