NorwayRevisorforeningen
Budget 2027 tax rest: paid-up capital deferred, NOK 6.4bn income-tax cut
Paid-up capital rules deferred past 2027 with an anti-avoidance warning; Skattefunn group cap defined with auditor attestation; income tax cut NOK 6.4bn; wealth-tax rates held; ASK extended to Euronext Growth.
By Taxxa AI OyPublished 7 October 2026
The 2027 budget's tax package reaches beyond the company-car model, the Skattefunn tightening and the excise programme covered in companion reporting. Its most watched non-decision is the deferral of new rules on skattemessig innbetalt kapital: the ministry's 15 October 2025 consultation proposed changes from 2027, but the proposal is still under considerationRevisorforeningen, so no change takes effect 1 January 2027
Revisorforeningen. The ministry stresses that the statutory anti-avoidance rule can apply to tax-motivated adaptations, citing Borgarting lagmannsrett's 24 November 2025 judgment (LB-2024-93254), now final. The consultation had sketched two equal alternatives — tax-free withdrawal of previously paid-up capital capped at the shareholder's input value, or tax freedom up to input value regardless of what was paid in — and Revisorforeningen backed the second as the simplest for taxpayers and Skatteetaten alike.
On Skattefunn, this account adds enforcement detail to the group-wide NOK 25 million ceilingRevisorforeningen: «consern» means controlling influence or a voting majority
Revisorforeningen, as in aksjeloven § 1-3; the auditor must check and attest that the group stays within the combined ceiling
Revisorforeningen, with the ministry to consider in the regulations how group companies and the auditor can practicably obtain and share the needed information; and the new group ceiling does not affect projects approved by the Research Council before 1 January 2027. The NOK 25 million cap is reduced pro rata in the start-up and closing years, relief is denied for costs incurred before project approval, the non-EEA-without-treaty exclusion is extended from purchased services to all R&D costs, and applicants must disclose project personnel so the authorities can verify sufficient resources.
Income tax falls by about NOK 6.4 billion in 2027Revisorforeningen: trygdeavgift on salary, benefits and business income drops 0.2 points
Revisorforeningen and personfradraget rises to NOK 120,180
Revisorforeningen, about NOK 1,200 above ordinary indexation. Wealth-tax rates are held unchanged
Revisorforeningen pending the political handling of NOU 2026: 9, as are the trinn-2 threshold at NOK 21.5 million and the NOK 14 million primary-home low-valuation limit; only bunnfradraget is raised, to NOK 1,990,000
Revisorforeningen. The aksjesparekonto extension to shares and equity certificates traded on multilateral trading facilities such as Euronext Growth
Revisorforeningen — consulted on until 3 August 2026, applying from 1 January 2027, against a base of almost 2.2 million accounts holding nearly NOK 500 billion at end-2024 — is proposed from 2027, with bonds and bond/combination funds still under study. And gains and losses on inherited or gifted homes and holiday homes realised within one year of succession or gift would both go untaxed and unrelieved, mirroring the transferor's position.
Legal basis: aksjeloven § 1-3 for the group definition used in the Skattefunn ceiling; skatteloven § 10-21 carries the existing aksjesparekonto rules the extension builds on; the Skattefunn enforcement detail amends skatteloven § 16-40 and FSFIN.
Adapt advice to deferred paid-up-capital rules with a sharper anti-avoidance focus, prepare group clients for the combined Skattefunn ceiling with auditor attestation, and update 2027 rates and allowances.