Norway’s 2027 budget: R&D restrictions and business tax proposals

Prop. 1 LS (2026–2027), approved in the Council of State that day, retains the ordinary 22% corporate income tax rate while proposing changes across corporate and business taxation. The legislative changes remain subject to parliamentary approval, with separate commencement and transition rules.^[1][5]

R&D relief restrictions

Skattefunn R&D relief would face a NOK 25 million annual eligible-cost ceiling across all group companies under section 16-40 of the Tax Act (Act of 26 March 1999 No. 14). The 19% credit rate is unchanged. Pre-approval costs would become ineligible, and the ceiling would be prorated by project months in the start and closing years. The group ceiling and proration have transitional protection for projects approved before 1 January 2027; otherwise the changes apply from the 2027 income year.^[4][5]

The R&D package extends geographic restrictions beyond purchased research services to other costs from outside the EEA where Norway has neither a tax nor information-exchange agreement. It expands Research Council/tax authority information-sharing powers. Separate planned regulation changes cover project personnel, board-approved financing plans, related-party cost documentation and prototype-income adjustments. Groups would need to review project timing, combined cost ceilings and overseas costs.^[4][5]

Aquaculture production tax

For aquaculture, proposed Tax Act section 19-9 would restrict the production-tax credit against resource-rent tax to production under permits within that tax’s scope. Production tax on other permits would instead be deductible under the ordinary income-tax rules. The bill proposes 2027 application. This changes the kind of relief available and requires permit-level allocation.^[4][5]

Pillar Two safe harbours

Pillar Two changes would add chapter 8 to the Supplementary Tax Act (Act of 12 January 2024 No. 1). Six permanent safe-harbour powers cover simplified effective tax rates, qualified domestic top-up tax, Side-by-Side, ultimate-parent-entity relief, substance-based tax incentives and simplified calculations; a separate power covers the transitional country-by-country-reporting safe harbour. Eligibility would still depend on implementing regulations, and incentive relief is limited to top-up tax attributable to qualifying incentives.^[2][5]

Those Pillar Two provisions would apply for 2026, to financial years beginning after 31 December 2025; existing section 5-7 would be repealed on 4 January 2027. The Tax Payment Act (Act of 17 June 2005 No. 67), section 10-53(4), and Tax Administration Act references would be aligned with chapter 8. The bill also corrects Supplementary Tax Act wording on reinvested physical assets and joint ventures.^[2][3][4][5]

Technical corporate tax corrections

Other Tax Act corrections address aquaculture-permit debt valuation (section 4-19), the fund exemption reference in exit taxation (9-14), shareholder relief and fund distributions (10-12 and 10-13), hydropower construction deductions (18-3), and wind-farm transfers of carried-forward production tax (18-10). These are reference or wording corrections proposed to commence on enactment. The paid-in-capital reform remains under review: chapter 16 expressly postpones the previously contemplated 1 January 2027 changes.^[4][5][6]

Company cars and VAT

For employers, section 5-13 would value private company-car use at 20% of original list price plus an engine-specific cost amount from 2027. For indirect tax, VAT Act (Act of 19 June 2009 No. 58) section 6-8 would reduce the electric-car exemption ceiling from NOK 300,000 to NOK 150,000 from 1 January 2027, with transitional leasing protection; section 6-28 would expand relief for documented outbound postal transport.^[4][5]

Customs, excise and sector charges

Remaining clothing/textile tariffs would fall to 5%, and seven fish/marine tariff lines to zero. Other business measures include CO2 tax increases and sector-specific rates, broader electric-van insurance-tax exemption, wider sugar-tax input relief, and sector-fee changes. Petroleum CO2 tax administration would move to the Excise Duty Act (Act of 19 June 2026 No. 41), including operator registration and licensees’ joint liability, from 1 January 2027.^[4][5]

Tax administration and filing

Eligible public and private/non-profit VAT-compensation claimants would gain three-year filing and self-amendment periods from 2027, with auditor confirmation and revised payment/interest rules. Tax Payment Act audit, Svalbard withholding and limitation references are also corrected. MNE groups should assess business, sector and procedural measures alongside Pillar Two, using each provision’s commencement rules.^[4][5]