Popular investment vehicles in Norway
- Norwegian limited company (Aksjeselskap)
- Norwegian internal partnership (Indre selskap)
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
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.
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
Norwegian limited company (Aksjeselskap)
- Yes (but would be highly unusual)
Norwegian internal partnership (Indre selskap)
Norwegian limited company (Aksjeselskap)
Norwegian internal partnership (Indre selskap)
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)
Norwegian limited company (Aksjeselskap)
Norwegian internal partnership (Indre selskap)
Norwegian limited company (Aksjeselskap)
Norwegian internal partnership (Indre selskap)
- Flexible and high resemblance to limited partnership
- Tax transparency
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)
Norwegian limited company (Aksjeselskap)
Norwegian internal partnership (Indre selskap)
Johan Svedberg
Partner
Oslo
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