Estonian Company Run from Norway: Tax Residence

Many Norwegian entrepreneurs form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Norway. That works, but Norwegian tax law does not look only at where a company is registered: a company with its real management (reell ledelse) in Norway is resident there. Norway's rules on Norwegian-controlled companies in low-tax countries (the NOKUS rules) can also tax a Norwegian owner — individuals included — on the company's profit. The tax treaty between Estonia and Norway leaves a company resident in both countries to the two tax administrations. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask a Norwegian tax adviser (skatterådgiver) before you form or buy the company. We read the Tax Act (skatteloven, act of 26 March 1999 no. 14, as last amended by the act of 23 June 2026 no. 66) on the official Norwegian law site Lovdata, and the treaty in its Estonian text in Riigi Teataja, on 21 October 2026; the English wording below is our translation.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Norway: founded under Norwegian law, or real management in Norway

Resident companies. Limited companies and comparable companies are liable to tax if they are resident in Norway (Tax Act, section 2-2(1)), and the liability covers all their capital and income in Norway and abroad (section 2-2(6)).
When a company is resident. A company is regarded as resident in Norway if it is founded under Norwegian company law or has its real management in Norway; to judge whether real management is in Norway, regard is had to where management at board level and day-to-day management are exercised, but also to other circumstances of the company's organisation and business (section 2-2(7)).
The treaty decides in the end. A company with its real management in Norway is nevertheless not regarded as resident in Norway if, under a tax treaty, it is resident in another state (section 2-2(8)).

In Norway: the NOKUS rules for Norwegian owners

For any Norwegian owner, individuals included. An owner who directly or indirectly owns or controls a Norwegian-controlled company resident in a low-tax country is taxable on a proportionate share of the company's profit, whether or not anything is distributed (Tax Act, sections 10-60 and 10-61).
Norwegian control. Norwegian control exists where at least half of the company's shares or capital are directly or indirectly owned or controlled by Norwegian taxpayers at both the beginning and the end of the income year (section 10-62(1)).
Low-tax country. A country is a low-tax country if the ordinary income tax on the company's total profit is less than two thirds of the tax it would have paid if it had been resident in Norway (section 10-63).
Two exceptions. The rules do not apply when the company is covered by a Norwegian tax treaty and its income is not mainly of a passive nature, or when the owner documents that the company is really established in an EEA state and carries on real economic activity there (section 10-64).

An Estonian company pays corporate income tax only when it distributes profit, so in a year in which it keeps its profit its tax can be below two thirds of the Norwegian tax. Estonia has a tax treaty with Norway and is an EEA state, so the two exceptions are where the analysis starts; your Norwegian tax adviser answers that with your facts and figures.

What the Estonia–Norway tax treaty says

Resident in both countries. If a person other than an individual is resident in both states, the competent authorities endeavour to settle the question by mutual agreement and decide how the agreement applies to it; without such an agreement the person is, in each state, not regarded as a resident of the other state for the agreement (agreement signed in Oslo on 14 May 1993, article 4(3); RT II 1993, 32, 108).
Permanent establishment. A permanent establishment is a fixed place of business through which the business of an enterprise is wholly or partly carried on; it includes especially a place of management, a branch and an office (article 5(1) and (2)). The profits attributable to it may be taxed in the state where it is (article 7(1)).
Directors' fees. Fees a Norwegian resident receives as a member of the management board or a similar body of an Estonian company may be taxed in Estonia (article 16) — see board member fee or dividend from abroad.
Dividends. Dividends paid by an Estonian company to a Norwegian resident may be taxed in Norway; if Estonia also taxes them at source, the treaty limits that tax to 5 percent of the gross amount for a company holding directly at least 25 percent of the capital, and 15 percent in all other cases (article 10(1) and (2)).

So the treaty does not settle a double residence by itself: a company with its real management in Norway may need an agreement between the two tax administrations. The multilateral convention on tax treaty measures (MLI) can change the rules of tax treaties; how it applies to your company is a question for your Norwegian tax adviser — we do not give that ruling.

What to decide before you form or buy the company

Where management is really exercised. Board-level and day-to-day management are what the Norwegian rule looks at first.
What the company earns, and what it has in Estonia. Passive income and real establishment decide whether the NOKUS exceptions apply.
Where the work is done. An office or other fixed place of business in Norway can be a permanent establishment.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Norwegian tax returns and Norwegian tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Norwegian tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Norway if I run it from Norway?

It can be. A company is resident in Norway if it is founded under Norwegian company law or has its real management in Norway — board-level and day-to-day management (Tax Act, section 2-2(7)) — unless a tax treaty makes it resident in another state (section 2-2(8)). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). Under the Estonia–Norway tax treaty the competent authorities endeavour to settle such a double residence by mutual agreement (article 4(3)). Norway's NOKUS rules can tax a Norwegian owner on the profit of a Norwegian-controlled company in a low-tax country, with exceptions for treaty countries without mainly passive income and for real establishments in the EEA (sections 10-60 to 10-64). Ask a Norwegian tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Norway: where it is taxed