I am a UK citizen who is tax resident in Norway and I own an apartment in Norway. I want to understand if it is possible to leave Norway and stop being tax resident without selling my house (i.e. let it out).
The only information I can find comes from KPMG which says:
"Termination of residence in Norway for persons with a total stay in Norway not exceeding 10 years happens when the following requirements are fulfilled:
- permanent stay in a foreign country
- stay in Norway must not exceed 61 days within a 12-month period
- do not have the disposal of a permanent home in Norway"
But this doesn't specify whether 'disposal' means 'owns' or 'uses'. Does anyone have any experience of this situation, or links to credible sources?
I found a better reference in KPMG Tax Facts Norway 2014 that says this: "To be regarded as emigrated from Norway, an individual who has had a combined stay in Norway for less than 10 years must take permanent residency outside of Norway. The taxpayer or his/her closest relatives must not have a residency used as a permanent home at their disposal in Norway or stay for more than 61 days in Norway during the income year."
When I contacted Skatteetaten (the Norwegian tax authority) by email they said this: "You will be tax resident as long as you keep your apartment in Norway, if you do not keep it you will not be tax resident in Norway. Persons who have lived in Norway for less than 10 years, will not be tax resident to Norway the first year they move, if they do not own their own apartment in Norway. Regards Skatt Midtnorge."
Nordisk eTax, a collaboration that includes Skatteetaten, says "the requirement that you must not have a house/flat at your disposal means that neither you, nor your spouse/cohabitant or your under-aged children can own (directly or indirectly), lease or otherwise be entitled to use a house/flat in Norway."
The answer still seems vague.