Holding structure
Organise your ownership optimally with a holding structure. Use the participation exemption and pay 0% tax on dividends between companies.
What is a holding company?
A holding company is a private limited company that primarily owns shares in other companies (subsidiaries), rather than conducting operational business itself.
The holding structure is the most common way to organise ownership in Norwegian business. It provides a number of tax and structural advantages.
Typical structure: You as a private individual own the holding company, which in turn owns one or more operating companies. Dividends from the operating companies flow up to the holding company almost tax-free – thanks to the participation exemption.
The participation exemption
Almost tax-free dividends between companies
The participation exemption (Section 2-38 of the Tax Act) means that private limited companies can normally receive dividends and gains from other private limited companies almost tax-free. Only 3% of the dividend is included as income, giving an effective tax rate of approx. 0.66%.
This makes it possible to accumulate capital in a holding company and reinvest in new projects without significant tax loss.
By comparison, dividends to private individuals are taxed at 37.84% (2024).
Tax rates
Typical holding structure
When is a holding structure appropriate?
Reinvestment of profits
Withdraw dividends from the operating company to the holding company almost tax-free and reinvest in new projects.
Risk separation
Keep capital safely in the holding company, separated from operational risk in the operating company.
Property investment
Purchase properties via separate SPV companies under the holding for optimal structure.
Generational transfer
Transfer shares in the holding company to the next generation under favourable tax rules.
Exit planning
Sell the subsidiary tax-free from the holding company (participation exemption on gains).
Co-owner arrangements
A holding structure makes it easy to regulate rights between multiple owners.
Ready for a holding structure?
Order a holding company with subsidiaries directly from Skraib. Ready in 1–3 business days.
Order holding structure