Structuring Your Dutch Business for Norway: Tax Optimization & Mortgages

Moving your business to Norway involves more than just registering a new entity. For established entrepreneurs from countries like the Netherlands, a successful transition requires a nuanced strategy that leverages both Norwegian and international tax rules.

Here are a few specific, advanced strategies based on real-world cases. You can read a lot more in our guide on doing business in Norway and also our Dutch guide on starting a business in Norway as a Dutch business owner.

You’re right. Let’s use a title that is more direct and professional, reflecting the strategic nature of the advice.

Relocating a business from the Netherlands to Norway involves specific tax and banking hurdles. Standard advice is often too general. This is a concrete briefing on the structural changes you need to consider for a successful move.

On Your Dutch Sole Proprietorship (Eenmanszaak)

  • Action: Do not create a Norwegian sole proprietorship (Enkeltpersonforetak – ENK). Convert your business into a Norwegian limited company (Aksjeselskap – AS).
  • Reasoning: The significant tax deductions for sole proprietors in the Netherlands (zelfstandigenaftrek, startersaftrek, MKB-winstvrijstelling) do not exist in Norway. At a revenue level of €80,000+, the AS structure is financially superior. It allows you to pay yourself a stable salary, which is critical for mortgages and social security.

On Your Dutch BV

  • Action: Do not liquidate your operating BV. Keep it active in the Netherlands. Establish a new Norwegian AS to act as a holding company and transfer the ownership of the Dutch BV shares to this new Norwegian entity. Hire yourself as an employee in the Norwegian AS so you can benefit from sick leave, parental leave and other benefits.
  • Financial Outcome:
    1. Lower Corporate Tax: You continue to bill your Dutch clients from the Dutch BV, paying the lower Dutch corporate tax rate (19% on the first €200,000 of profit versus 22% in Norway).
    2. Tax-Free Profit Transfer: Under the Netherlands-Norway tax treaty, the after-tax profits from your Dutch BV can be paid out as dividends to your Norwegian holding company with next to 0% withholding tax.

On Getting a Norwegian Mortgage

  • The Problem: As a business owner, you will face significant challenges securing a mortgage from major Norwegian banks like DNB, Nordea, or Sparebanken. They are highly risk-averse towards non-salaried income.
  • The Solution: Do not waste time with the large banks initially. Approach banks known to be more accommodating to entrepreneurs’ financial profiles. Local banks such as some of the smaller banks in the Sparebanken network and more industry-specific banks BN Bank is a specific, practical example of a bank with a better understanding of this customer segment.

Securing a Loan Before You Move

For those looking to start a new business in Norway, the primary challenge is often securing a loan to buy a property before you are officially registered as a resident.

The D-Number Misconception

A common but incorrect assumption is that establishing an AS simply to obtain a temporary D-number will unlock financing. It won’t. Norwegian banks base lending decisions on Norwegian income history and local collateral, not on whether you have a temporary registration number. A D-number is a procedural step, not a solution to the core requirement of demonstrating financial stability within the Norwegian system.

The Importance of Regional Banks

The Norwegian banking landscape is not monolithic; it’s highly regional. While large national banks may have uniform policies, the many local savings banks (Sparebanken) operate with significant autonomy.

  • A Real-World Example: We recently advised a client who received loan offers from three different local banks in the Western Norway, despite not being a resident. When they found a property in a different region, they were rejected by six local banks there, all citing their non-resident status.

This demonstrates that your ability to secure financing can depend heavily on the specific region and the risk appetite of the local bank branch. There is no single national “yes” or “no.” If you are set on buying before you move, you must be prepared to contact a wide array of local banks in your target area.

One More Thing: A Combined Holding for Couples

For a couple moving together, combining your separate businesses under a single, shared holding company can be a powerful move.

A joint AS holding where both partners draw a salary can present a much stronger, unified financial picture to a bank. This can significantly increase the chances of a mortgage approval and may result in better terms. This is a critical factor to weigh when deciding on your final corporate structure.

This structure provides a robust and tax-efficient foundation. It requires coordination with tax advisors in both countries for correct implementation.

Ask our advisers

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Thomas

Thomas is the founder of NordicHQ. Get in touch

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