Norway applies company-level tonnage-tax flag requirement for 2026

Tax Act section 8-11(8) requires a company in Norway’s shipping tonnage-tax regime to maintain or increase the proportion of its net tonnage registered in the European Economic Area against its baseline at 1 July 2005, or against the entry-date proportion for a later entrant. The company-level test does not apply while at least 60% of its net tonnage is EEA-registered. Section 8-11(9) also suspends the test for a year if the regime-wide EEA proportion at the previous year-end was maintained or increased from the preceding year.^[1][2]

The regime-wide share fell below its 2024 level

The Administration recorded 6,785,375 net tons under EEA flags and 4,883,232 net tons under non-EEA flags at 31 December 2025. The resulting EEA share was 58.15%, down from 58.61% at 31 December 2024. Its data covered 838 limited companies and 71 participant-assessed entities. Because the aggregate share fell rather than holding or rising, the Administration states that the company-level flag requirement applies for the 2026 income year.^[1]

Group and restructuring rules affect the comparison

The Finance Ministry regulations define a company’s flag requirement by reference to the EEA share at the measurement date. Where a company controls another regime company, the Tax Act requires a consolidated calculation. The regulations base that ratio on the group’s combined EEA-registered and total baseline net tonnage, attribute all tonnage of a controlled participant-assessed or NOKUS entity to the controlling company, and prescribe recalculations for mergers, demergers and changes in group structure.^[2][4]

Shipping groups should therefore compare their 2026 fleet and group structure with the correct baseline and document the net-tonnage and flag data behind that comparison. A breach of sections 8-11 to 8-13 can cause exit from the regime under section 8-17(1). Section 8-17(3) nevertheless prevents exit for a remediable section 8-11 breach corrected within two months after it arose, with a separate discovery-based period for immaterial or uncontrollable breaches and a possible extension where timely correction would cause particular difficulty.^[3][4]