Not tax or legal advice. This page sorts public sources, as of 1 Nov 2026. Whether and how any of it applies to you is a question for your tax adviser.
In short
- Norway taxes unrealised gains on shares and similar holdings when you move away. For moves from 20 Mar 2024 a 12-year rule applies. It is law in force.
- Basic deduction: NOK 3m on the total unrealised gain. The tax can be paid at once, in interest-free instalments over 12 years, or deferred. If you return within 12 years still holding the shares, it isn't owed.
- Since 7 Oct 2024, 70% of distributions must go towards the deferred tax.
- The tax commission (NOU 2026: 9) recommends relief. These are recommendations, not law. We found no exit tax change in the 2027 budget bill.
- The Tax Administration can require security even for moves within the EEA. For Liechtenstein, please check case by case.
Status check 1 Nov 2026
What applies in Norway, and what's being debated?
Sorted, with sources. Law in force and recommendations are kept apart.
NOlaw
Exit tax since 20 Mar 2024
- Unrealised gains are assessed on departure, NOK 3m basic deduction (Skatteetaten).
- Pay at once, in interest-free instalments over 12 years, or deferred. Return within 12 years with the shares: the tax lapses.
- Since 7 Oct 2024: 70% of distributions go towards the deferred tax.
- The Tax Administration can require security even for moves to an EEA state. Under the older rules, security was expressly required for Liechtenstein (Skatteetaten, Norwegian).
NOgovernment bill
2027 budget: wealth tax
- Presented on 7 Oct 2026 (Prop. 1 LS, Norwegian). Total rate 1.0%, above NOK 21.5m 1.1%.
- The allowance would rise from NOK 1.9m to NOK 1.99m, NOK 3.98m for married couples (NRK, Norwegian).
- Dividends and share gains: 37.84% effective (2027 tax rates, Norwegian).
- As far as we found, the bill contains no change to the exit tax.
NOrecommended
Tax commission NOU 2026: 9
- Handed over on 24 Jun 2026 (regjeringen.no, Norwegian). Recommendations only.
- Wealth tax: rates between 0.25 and 0.75%, no valuation discounts, allowance around NOK 2m, own home with an allowance of at least NOK 7m.
- Exit tax: share of distributions used for repayment cut from 70 to 37.84%, an exemption for temporary residents, a possible deduction for value losses within 3 years.
- A majority wants to keep the 12-year rule.
As of 1 Nov 2026. Exit tax: law in force. 2027 wealth tax: government bill. Commission: recommendation.
What it honestly means
Norway shows what an exit tax looks like in practice: long periods, clear rules, little room. Three things matter:
- Twelve years is a long time. If you move after 20 Mar 2024, the latent tax comes with you. If you're considering a move, run the numbers early and get advice in both countries.
- Substance, not a mailbox. An address alone is neither a residence nor a company seat. If you build something in Liechtenstein, you need a real presence: a registered company with its seat and desks on the ground, a team, and decisions made here. More: Substance in Liechtenstein.
- Plan for security and distributions. Norway decides whether and what security is required and how distributions trigger repayment. Double taxation questions come on top: Double taxation and Liechtenstein.
Why we still like talking about Liechtenstein: the environment is predictable. Founders plan in years, not in headline cycles.
Exit taxes in Europe compared
Almost everywhere, what grew in the old country is taxed. A short comparison as of 1 Nov 2026. Every country including wealth and data taxes: Tax news Europe.
| Country | Status 1 Nov 2026 | Source |
|---|---|---|
| Italy | Government bill, not law. 26% on unrealised gains from €800,000 in financial assets, resident 6 of 10 years, planned from 1 Jan 2027. | Il Sole 24 Ore |
| Germany | Law in force. From a 1% stake in a corporation and 7 of 12 years fully taxable: the gain in the shares is taxed on moving away. Instalments over seven years on application. | § 6 AStG (German) |
| France | Law in force, change at first reading. From €800,000 in securities, resident 6 of 10 years. Today the tax lapses after 2 or 5 years; on 30 Oct 2026 the Assemblée nationale adopted 15 years at first reading. | Amendment I-462 (French) |
| Norway | Law in force. Moves since 20 Mar 2024: unrealised gains above NOK 3m, payable within 12 years. | Skatteetaten |
| Belgium | Law in force since 2026. Exit tax as part of the 10% capital gains tax. Automatic deferral for EU and EEA states among others; not owed without a sale within 2 years. For Liechtenstein, check case by case. | SPF Finances (French) |
| Netherlands | Law in force for box 2. Leaving with a stake of 5% or more triggers a protective assessment (conserverende aanslag). Box 3 is being rebuilt; that is still in parliament. | Belastingdienst (Dutch) |
| Spain | Law in force. From €4m in shares and holdings, or more than 25% of a company worth more than €1m, resident 10 of 15 years. For moves to an EU or EEA state with exchange of information, by election only due on a sale within 10 years. For Liechtenstein, check case by case. | Art. 95 bis LIRPF (Spanish) |
| Austria | Law in force. Moving away counts as a disposal of capital assets, special rate 27.5%. For moves to an EU/EEA state, on application assessed only on an actual sale. For Liechtenstein, check case by case. | § 27(6) EStG (German) |
| Denmark | Law in force. From DKK 100,000 in shares and usually after 7 years of tax liability, gains count as realised on departure. Interest-free deferral; security required outside the EU and the Nordic countries. For Liechtenstein, check case by case. | Skattestyrelsen (Danish) |
| United Kingdom | No general exit tax. If you return within 5 years, gains made while abroad can be taxed (temporary non-residence). | gov.uk HS278 |
| Ireland | No general exit tax. Return rule for domiciled individuals after no more than 5 years away (holdings of 5% or more, or over €500,000). | Revenue s. 29A |
| Switzerland | No general exit tax for individuals. According to the Federal Department of Finance, the Federal Council considers one ruled out under the constitution. | Federal Department of Finance (German) |
The basics: Exit tax.
Liechtenstein in numbers
| Item | Status | Source |
|---|---|---|
| Corporate income tax | 12.5%, since 2011 (Tax Act in force since 1 Jan 2011) | llv.li, gesetze.li SteG |
| Minimum corporate income tax | CHF 1,800 a year | llv.li |
| EEA | Member since 1995 | gesetze.li |
| Currency | Swiss franc (CHF) | – |
| Blockchain Act (TVTG) | in force since 2020 | gesetze.li |
| GmbH (LLC) | from CHF 10,000 share capital | GmbH fact sheet, llv.li |
| EU list of non-cooperative tax jurisdictions | Liechtenstein is not on it (update 9 Oct 2026) | Council of the EU |
It's not a hack. It's boringly predictable, and that's the point. How incorporation works: GmbH formation in Liechtenstein.
digihub · In der Specki 3, Schaan
Substance means a real place to work
If you're looking at Liechtenstein seriously, you need more than an address: an office, people on the ground, decisions made here. At digihub in Schaan you get real desks, not a mailbox: coworking with a Flex Desk from CHF 169, a Full Desk from CHF 299 or a Private Office from CHF 549 a month, plus meeting room and community. A business address is available by agreement (Registered office & business address).
Come by for a coffee, and we'll see together whether Liechtenstein even makes sense for you.
Read next
- Tax news Europe: all countries at a glance
- Italy exit tax: what the draft says
- France exit tax: 15 years at first reading
- Belgium: 10% capital gains tax and exit tax
- Netherlands: box 3 in parliament
- UK: Founders' Relief and non-dom
- Spain: solidarity tax and exit tax
- Switzerland: JUSO initiative rejected, what applies now
- Austria: inheritance tax called for, exit tax applies
- Denmark: no wealth tax, inheritance duty proposed
- Ireland: 31% capital gains tax in Budget 2027
- Exit tax: the basics
- What does substance mean in Liechtenstein?
- GmbH formation in Liechtenstein
Sources
- Skatteetaten: Exit tax
- Skatteetaten: Exitskatt (Norwegian)
- regjeringen.no: NOU 2026: 9, tax commission (24 Jun 2026, Norwegian)
- regjeringen.no: Prop. 1 LS (2026–2027), taxes and duties (Norwegian)
- regjeringen.no: 2027 tax rates (Norwegian)
- NRK: wealth tax allowance to rise (Norwegian)
- llv.li: corporate income tax (German)
- Council of the EU: EU list of non-cooperative jurisdictions, update 9 Oct 2026
- llv.li: GmbH fact sheet (German)
Not tax or legal advice. Orientation based on public sources, as of 1 Nov 2026. Please check your own case with a tax adviser or lawyer in Norway and Liechtenstein.
Content from digihub.li · reviewed 1 November 2026.