New tax on foreign income in the economic zone and continental shelf

In 2024, a new provision was introduced that extends the tax obligation to foreign companies involved in mineral activities, renewable energy, and carbon management in Norwegian maritime areas beyond the territorial border. In the 2025 budget proposal, it is suggested that this tax obligation be extended further to include foreign actors in aquaculture and related businesses. The goal is to ensure that Norwegian and foreign companies are treated equally when it comes to income taxation from activities within the 200-mile zone and on the continental shelf. Let’s take a closer look at what this means for you.

Tax obligation for foreign companies in offshore mineral and energy operations

In 2024, legal provisions in the Taxation Act were introduced for taxing foreign companies’ income from mineral activities, renewable energy resources, and carbon management in the 200-mile exclusive economic zone and on the continental shelf. Initially, the amendment applied only to foreign companies’ income related to the above activities and did not include aquaculture outside Norwegian territorial waters.

Tax obligation for foreign actors in aquaculture and offshore operations

In the longer term, increased activity is expected in the exclusive economic zone and on the Norwegian continental shelf, particularly as new technology and aquaculture installations are developed, enabling operations further offshore.

To ensure tax liability to Norway and equal treatment of Norwegian and foreign companies, it is proposed to introduce limited tax liability for foreign entities’ income from aquaculture and associated activities beyond the Norwegian territorial waters.

The proposal is notably broad in its scope and extends to work related to the core activities performed at the aquaculture facilities.

Additionally, it is proposed to introduce a legal basis for taxing foreign employees' income from work related to mineral activities, renewable energy resources, carbon management, aquaculture, and associated activities.
These changes are proposed to take effect starting from the 2025 tax year.

Limitations on Taxation Rights through Tax Treaties

Norway has tax treaties with approximately 90 countries, which may limit Norway’s right to impose the proposed taxes. In many of these treaties, the continental shelf and the exclusive economic zone are not included in the definition of "Norway." To avoid double taxation, each tax treaty should be scrutinized. 

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