Norway does not let go of you when you board the plane. Two things follow you: your tax residence, which ends only when you prove that the statutory conditions are met, and the exit tax on gains in shares you own when it ends. Both have to be settled before a US LLC run from abroad does what you set it up to do.
Who Norway treats as resident
Under section 2-1 of the Tax Act (skatteloven) you are resident if you stay in Norway for more than 183 days in any 12-month period, or for more than 270 days in any 36-month period. Under the second test, residence starts only in the income year in which the day count is exceeded.
A resident is taxable on all wealth and income, in Norway and abroad. Liability to wealth tax depends on living in Norway on 31 December of the year before the assessment year. And moving away changes nothing on its own: according to Skatteetaten, you remain taxable on your worldwide income and wealth after you have moved abroad, until tax emigration has been granted.
When residence ends: 61 days and no dwelling
For someone who settles permanently abroad, residence ends for the income year in which it is proven that
- you stayed in Norway for no more than 61 days in total in that income year, and
- neither you nor your close relatives had a dwelling at your disposal in Norway.
The dwelling test has an absolute edge: residence never ends before you and your close relatives no longer have a dwelling in Norway at your disposal. The statute defines both terms widely:
- Close relatives means your spouse, cohabitant or minor children.
- Having a dwelling at your disposal means owning it, renting it or otherwise having a right to use it, directly or indirectly.
So the house your spouse keeps living in, or the apartment you rent for your visits: each one blocks the exit. Two things do not. A leisure home (fritidsbolig) can be kept, Skatteetaten says, and you can still be tax emigrated. And a dwelling acquired at least five years before the year you move abroad, which neither you nor your close relatives used as a home during that period, does not count as a dwelling for this test.
Counting days is strict: every started day in Norway counts as a full day.
Two steps are separate and both are yours. Reporting your move to the National Population Register (Folkeregisteret) does not end your Norwegian tax liability. Tax emigration is claimed in your tax return (skattemeldingen), under "Krav om skattemessig emigrasjon".
Resident for ten years or more: three more years
If you were resident in Norway for at least ten years before the income year in which you settle abroad, a longer rule applies. Your residence ends only after the end of the third income year after the year of the move, and only if for each of those three years it is proven that you stayed no more than 61 days in Norway and that no dwelling was at the disposal of you or your close relatives.
In practice: if you move in 2027 after ten years in Norway, your residence can end at the earliest after 31 December 2030, and only if 2028, 2029 and 2030 each pass both tests. One year with 62 days, or one year with a flat at your spouse's disposal, and the clock has not run out.
The exit tax on share gains
Section 10-70 of the Tax Act taxes gains on covered assets you own when your Norwegian tax liability ends under section 2-1 (3), or when you become resident in another state under a tax treaty. The gains are taxed as if you had sold the assets on the last day before that time.
What is covered: shares and holdings in Norwegian companies and in corresponding foreign companies, plus share savings accounts, options and similar instruments.
The threshold: on moving out, the tax applies only to the part of your total net gain, after deductible losses, that exceeds NOK 3 million. This version of section 10-70, with the NOK 3 million threshold and the 12-year rules, applies to moves and transfers on or after 20 March 2024 (amending act of 20 December 2024 no. 86).
Losses: latent losses are deductible only on a move or transfer to another EEA state. On a move outside the EEA, Skatteetaten adds up all latent gains and does not count losses. The United States is outside the EEA.
Assets you brought with you: for assets you owned when you moved to Norway, the opening value is their market value at the time you became resident.
Whether an interest in your US LLC counts as a holding in a "corresponding foreign company" is not answered in the sources checked for this page. Treat it as a question to settle before you move, not as an escape route.
No lapse with time. For moves from 29 November 2022 the exit-tax liability no longer has a time limit; before, it lapsed after five years. The tax now lapses only if you become resident in Norway again, or treaty-resident in Norway, within 12 years after the end of the year the exit tax is allocated to, and only for the assets you still own when you return.
Deferral: 12 years, with security outside the EEA
You can be granted 12 years to pay, counted from the end of the year the exit tax is allocated to. The condition is adequate security for the tax and any interest. For moves to another EEA state, security is required only where there is a real risk the claim cannot be collected. A move to the US is outside the EEA, so security is required.
Under deferral you choose between paying one twelfth each year, or paying the whole amount at the end of the 12 years with interest from the date the tax would otherwise have been due.
The deferral is not unconditional:
- it ends on sale, on your death, or on transfer of the asset to a person or entity outside Norwegian tax liability;
- dividends and similar distributions on assets carrying deferred exit tax end the deferral for an amount equal to the distribution multiplied by 0.7;
- you must report all relevant information unprompted, and breaching that duty ends the right to deferral;
- every year by 30 April you confirm your country of residence and that you still hold the assets, and you report changes within two months.
The exit-tax details go into the tax return for the year that includes the day before the move. If you do not report the exit tax there, Skatteetaten can assess it up to 15 years after the move; the earlier limit was five years.
The right sequence
What goes wrong if you skip a step
- You keep a flat, or your spouse, cohabitant or minor children keep one: your residence does not end.
- You were resident for ten years or more and expect to be out after one year: the rule runs for three full income years after the move year.
- You spend 62 days in Norway in one of those years: that year fails the test.
- You report your move to Folkeregisteret and stop there: your tax liability continues until tax emigration is granted.
- You leave the exit tax out of the return: it can be assessed for up to 15 years.
- You miss the 30 April confirmation or another reporting duty: the deferral ends.
- You take dividends on shares carrying deferred exit tax: 0.7 times the distribution becomes payable.
How the LLC itself is taxed in the US is explained in how the LLC is taxed. Leaving a neighbouring country instead? See Sweden, Denmark and Finland.
Sources
Checked 26 October 2026.
- Skatteloven (Tax Act, LOV-1999-03-26-14) § 2-1: lovdata.no
- Skatteloven § 10-70, with the amendment note to the act of 20 December 2024 no. 86: lovdata.no
- Folkeregisterloven (LOV-2016-12-09-88) § 6-3: lovdata.no
- Skatteetaten, "Skattemessig emigrasjon": skatteetaten.no
- Skatteetaten, "Globalskatteplikt": skatteetaten.no
- Skatteetaten, "Utflyttingsskatt, exitskatt": skatteetaten.no
- Skatteetaten, "Flytte fra Norge": skatteetaten.no
Your own case
This page is general information, not advice on your case. Your residence years, your holdings and your timing are checked in the consultation, held in English.
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