Last week, the government presented proposals for changes to the rules for relocation tax.
Linda Hjelvik Amsrud, head of the legal department and lawyer at Nordea Private Banking, reacts particularly to the point in the proposal which states that if the taxpayer dies abroad, the expatriation tax is still due for payment, writes E24.
– If you are unlucky enough to die while living abroad, the new proposal means that you will receive a large tax bomb after death has occurred. This is perhaps the most important and most dramatic point in the new proposal, says Amsrud to E24.
– Hidden form of inheritance tax
She believes this could lead to more people being unsure whether they dare to live temporarily abroad for a period of time.
– This proposal entails a hidden form of inheritance tax. If the holder of the shares dies, the person in question is still subject to a tax of close to 38 per cent on the gain on the shareholding. In practice, this can be perceived as a form of inheritance tax, since the tax is transferred to any children or spouses, says Amsrud to E24.
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– Direct consequence of the government’s policy
A main move in the government’s proposal is to limit the postponement of payment of the fixed relocation tax to twelve years. The person who must pay the tax is given the choice between paying the tax immediately in interest-free installments over twelve years, or at the end of the twelve-year period with added interest. If the taxpayer moves back with the share within twelve years, the tax is waived or refunded.
Conservative deputy leader Tina Bru. Photo: NTB
The proposals are now sent for consultation. The deadline for submitting consultation responses is 21 May 2024.
The Conservative Party believes the proposal could have unintended consequences, such as the risk of double taxation.
– This proposal is a direct consequence of the government’s tax policy which makes it less attractive to invest and save money in Norway, said Conservative Party deputy leader Tina Bru when the proposal became known.
