Norway charges exit tax on the unrealised gain in shares and similar holdings when a person stops being tax-resident there. Section 10-70 of the Taxation Act treats the assets as sold the day before. Only gain above 3 million kroner is taxed on an emigration, and payment falls due within twelve years, with deferral conditional on security.
Norway does not wait for you to sell. If you were tax-resident in Norway and that residence ends, the law treats the shares and similar holdings you still hold as sold the day before. It works out the gain and charges tax on it. The charge is called utflyttingsskatt in Norwegian, and it lives in section 10-70 of the Taxation Act. Australia sits outside the European Economic Area (EEA), and that puts you on the harder side of several rules inside the section.
Key Takeaways
- Section 10-70 makes the gain taxable, in translation, as though the asset had been realised on the last day before your Norwegian tax liability ended, or before the day you are treated as resident in another state under a tax treaty.
- On an emigration, only the part of total gain above 3 million kroner is taxed. On a transfer of assets to someone abroad the rule is a trigger instead: once net gain or loss passes 100,000 kroner, the whole gain is taxed.
- Losses are deductible on a move to another EEA country. Australia is outside the EEA, so the Tax Administration adds up gains there and leaves losses out.
- The tax may be paid over twelve years, and deferral requires adequate security. Inside the EEA, security is asked for only where collection is genuinely at risk.
- Becoming tax-resident in Norway again within twelve years cancels the charge on the assets you still hold, and the interest with it.
The charge is on a sale that has not happened
Section 10-70 states its mechanism in one sentence. A gain is taxable on a covered asset you own at the point your Norwegian tax liability ends, in translation as though the asset had been realised on the last day before that point. The same applies where you are to be treated as resident in another state under a tax treaty. The sale is invented. The gain and the assessment that follows it are not.
The list of assets in the second paragraph is wider than most people expect. It covers shares and equity certificates in Norwegian companies, holdings in the same kinds of foreign company, units in partnerships, subscription rights, options and other instruments built on those, share savings accounts, and capital insurance of the kind the Act describes. The Norwegian Tax Administration adds the practical items: units in securities funds, options in an employment relationship, contracts for difference, exchange-traded funds, which its list calls foreign ETFs, warrants, and assets in a foreign pension savings scheme treated as an ordinary investment account. It names American individual retirement accounts and 401(k) plans as examples.
What is not on the list matters as much. An ordinary bank balance is not covered, so money already sitting in a Norwegian account is outside this charge.
When Norway decides you have left
Two events can trigger the section, and they do not arrive together.
The first is treaty residence. The convention between Norway and Australia was signed on 8 August 2006 and came into force on 12 September 2007. Its Article 4 defines a resident of Australia as a person resident there for Australian tax, and sets tie-breakers where both states would claim you. The day it makes you an Australian resident is a day section 10-70 names.
The second is emigration under Norwegian domestic law, and that arrives slowly. Telling the National Population Register you have moved ends nothing. In the Tax Administration's words, until the cessation of your tax residency gets approved, you have a global tax liability to Norway.
How long you wait depends on how long you lived there.
| Total residence in Norway | When tax liability can end |
|---|---|
| Ten years or less | Once you live abroad permanently, have not spent more than 61 days in Norway in the year claimed, and neither you nor your related parties have access to any residential property in Norway |
| More than ten years | Three years from the moment you settle permanently abroad, with those same two conditions holding through each of the three years |
A holiday home is allowed. So is a house you have owned for at least five years, which neither you nor your related parties have used as a home in that time; the Tax Administration calls that the five-year rule. Related parties means spouses, cohabiting partners and underage children.
Three million kroner, and what being outside the EEA costs
The fourth paragraph sets two figures, and they work in opposite ways. On an emigration, liability is limited to the part of total gain, after deductible losses, that exceeds 3 million kroner. That is a deduction. On a transfer of a covered asset to someone abroad, liability applies to the whole gain once net gain or loss for the income year exceeds 100,000 kroner. That is a trigger, so crossing it taxes everything rather than the excess.
Then the EEA line falls across the arithmetic. The third paragraph allows a deduction for latent losses on a move or transfer to another EEA state. It withdraws that deduction if you then move outside the EEA before the deferral period ends. The Tax Administration works the same portfolio both ways:
| Portfolio line | Move inside the EEA | Move outside the EEA |
|---|---|---|
| Latent loss of 93,000 kroner | deducted | not included |
| Total gain | 3,412,200 | 3,505,200 |
| Basic deduction | 3,000,000 | 3,000,000 |
| Taxable part | 412,200 | 505,200 |
The threshold has moved too, so the date you left decides which rule reaches you.
| Move or transfer | Rule |
|---|---|
| On or after 20 March 2024 | Basic deduction of 3 million kroner on an emigration; on a transfer, the whole gain once net gain or loss passes 100,000 kroner |
| Before that date | Exit tax payable where net latent gain exceeded 500,000 kroner |
| On or before 28 November 2022 | The same, and the liability lapsed after five years |
Twelve years, and the three ways to pay
The seventh paragraph gives you up to twelve years, counted from the end of the year the exit tax is assigned to. It attaches a condition: adequate security for the liability and any interest. For a move or transfer to another EEA state, security is required only where there is a real risk the claim cannot be collected. Outside the EEA that qualification is absent, so security is the ordinary case.
Within the deferral you choose. The Act offers one twelfth each year, or payment at the end of the period, with interest running from the date the tax would otherwise have fallen due until it is paid. The Tax Administration adds paying immediately as a third option.
The eighth paragraph lists what ends the deferral early: realising the asset, your death, a transfer to a person or entity abroad, and the cessation of the business of a partnership on the asset list. A dividend does not end the deferral, but it reduces it. Where a distribution is made on an asset carrying exit tax, the right to defer lapses for an amount equal to the distribution multiplied by 0.7. The Tax Administration states the same rule as 70 per cent of the distribution going towards repayment of the claim, and adds that where you pay tax on the distribution in Norway and abroad, the repayment is limited so that you do not pay more than 100 per cent of the distribution in total.
What ends the charge, and the paperwork that keeps it alive
Returning ends it cleanly. Under the ninth paragraph, if you become resident in Norway again within twelve years of the end of the year the exit tax was assigned to, the taxation under the section lapses for every covered asset you still hold. Accrued interest goes with it. If you return after twelve years and have settled the exit tax in full, the original opening value of assets you still hold is adjusted by the change in value already taxed.
Keeping the deferral alive is an annual duty. The eleventh paragraph requires you, unprompted and without undue delay, to give the tax authorities every piece of information bearing on your rights and duties under the section, and the right to defer ends if you breach it. The administration asks for a confirmation each year by 30 April, naming your country of residence and confirming you still hold the assets, and for notice within two months where you no longer hold them or where you move from an EEA country to one outside it.
Where nothing about exit tax is reported in the return, the administration may assess it up to fifteen years after the move or transfer.
How Australia then treats those assets is a separate question, governed by Australian law and by the same convention, and it is not covered here. It is one for a registered tax agent who can see both sides. What section 10-70 decides is how much of the balance is yours to send.
Where to look next
- Receiving money from Norway - the live rate page for this corridor, and what a fixed krone amount converts to on the day.
- How international transfers work - the route a payment takes once the Norwegian tax position is settled.
- Understanding transfer fees - the separate cost of moving the money.
- How to find an accountant - checking a tax agent is registered, which matters where two countries both want a return.
- AUD to NOK - the convert page for this pair.
Sources
- Lov om skatt av formue og inntekt (skatteloven) section 10-70, Lovdata - the deemed realisation, the covered assets, the two kroner figures and their different shapes, the EEA condition on losses, the twelve-year deferral and its security condition, the payment methods and the interest rule, the lapse of deferral, the 0.7 multiplier, the cancellation on returning, the opening-value adjustment, and the disclosure duty.
- Exit tax, the Norwegian Tax Administration - who the rules reach, the asset list, the worked examples inside and outside the EEA, the pre-2024 branches, the 100 per cent cap on repayment out of a distribution, the annual confirmation by 30 April, the two-month notification, and the fifteen-year window.
- Tax emigration, cessation of tax liability, the Norwegian Tax Administration - that reporting a move does not end tax liability, the ten-year split, the three further years and the conditions holding through them, the 61-day limit, access to a residential property, the five-year rule and related parties.
- Overenskomst mellom Norge og Australia til unngaaelse av dobbeltbeskatning, Lovdata - the convention signed 8 August 2006, in force from 12 September 2007, and Article 4 on residence and the tie-breakers.
- Tax when you move abroad, the Norwegian Tax Administration - the continuing global tax liability after a move is reported, and pay earned before emigration but received after it.
General information about Norway's exit tax on shares and similar assets, and about when Norwegian tax residence ends. Not financial advice, not tax advice, and not a recommendation of any product or institution. Reviewed by the Tradergy editorial team, September 2026.
Common questions
Does Norway tax me when I move to Australia even if I have sold nothing?
Yes, if you hold assets the rule covers. Section 10-70 of the Taxation Act makes a gain on shares, share savings accounts and similar holdings taxable, in translation, as though the asset had been realised on the last day before your Norwegian tax liability ended. Nothing has to be sold for the charge to arise.
How much can the gain be before exit tax applies?
On an emigration, liability reaches only the part of total gain, after deductible losses, that exceeds 3 million kroner. The Norwegian Tax Administration calls it a basic deduction. On a transfer of assets to someone abroad the rule is different: once net gain or loss for the year passes 100,000 kroner, the whole gain is taxable.
Do I have to pay it straight away?
Not necessarily. The Act allows up to twelve years, counted from the end of the year the exit tax is assigned to, but deferral is conditional on adequate security for the tax and any interest, and outside the European Economic Area that condition is the ordinary case. Within the deferral you choose between paying immediately, one twelfth each year, or the whole amount at the end with interest.
What happens if I move back to Norway?
If you become tax-resident in Norway again within twelve years, section 10-70 provides that the taxation lapses for the assets you still hold, and so does the accrued interest. If you return later than twelve years and have settled the exit tax in full, the opening value of assets you still hold is adjusted for the change already taxed.
Does the exit tax reach an inheritance from Norway?
It can. The Tax Administration lists inheriting assets from someone who was subject to exit tax among the cases the rules reach. It also states that where the estate of a person who was tax-resident in Norway transfers assets to someone tax-resident abroad, the estate is liable for tax on latent gains and losses, and that an heir abroad may take over the deceased's tax positions.