Loan from an AS company to an owner or shareholder - tax consequences
Loan from an AS company to an owner or shareholder - tax consequences
ive been running an AS for a few months and finally had a bigger job recently and i want to transfer myself 150 000 NOK to renovate my flat. The accountant says it has to be shown as some kind of loan in Aksjo-whatsit and that there will be some tax? whats that about?
The owner of an AS may need money privately, while the company may have available funds in its account. A transfer described as a loan may then seem like a simple solution. However, Norwegian tax rules and company law impose specific conditions on such a payment.
In this article, we explain when a transfer from an AS is a shareholder loan, how much tax applies in 2026, when the exception for short-term loans applies, and what happens after the debt is repaid.
When is a transfer from an AS a shareholder loan?
In an AS, the owner is a shareholder and the company is a separate legal entity. Money in the AS account belongs to the company, so private withdrawals must have a proper basis, such as salary, dividends, expense reimbursement, or a loan.
The term aksjonærlån covers credit or security provided by an AS to an individual who is a direct or indirect shareholder. The rule also covers certain related persons and payments from another company belonging to the same group.
The following may be treated as a loan, among other things:
- a transfer from the AS account to the shareholder's private account,
- payment by the company of the owner's private invoice,
- a private purchase made with the company card,
- a negative balance in the owner's shareholder account,
- a guarantee by the AS for the shareholder's private loan,
- a transfer of money to an ENK operated by the shareholder.
An ENK is not a separate tax entity from its owner. A loan from an AS to your ENK is therefore treated as a loan granted to you personally, even if the funds finance business activities.
As a general rule, the special provision does not apply to a loan granted to a shareholder that is another company. However, such a transaction must still meet company law, market terms, and accounting requirements.
How is a loan taxed in 2026?
A loan granted by an AS to a shareholder who is an individual is generally taxed as a dividend when the money is made available. At the same time, it remains a genuine debt that the shareholder is required to repay.
In 2026, the taxable amount after deducting any available skjermingsfradrag (shielding deduction allocated to the shares) is multiplied by 1.72 and then taxed at 22%. The effective tax rate is 37.84%.
| Taxable loan amount | Basis after multiplication by 1.72 | Tax at a 22% rate |
|---|---|---|
| 50 000 NOK | 86 000 NOK | 18 920 NOK |
| 100 000 NOK | 172 000 NOK | 37 840 NOK |
| 150 000 NOK | 258 000 NOK | 56 760 NOK |
The table assumes that no shielding deduction is available. The possibility of using this deduction requires, among other things, that the loan is lawful under company law.
Tax arises in the year of each payment. You must not limit the assessment to the balance visible on 31 December. If you withdrew 200 000 NOK during the year and then repaid 150 000 NOK, all transactions must be reviewed, not only the final debt balance of 50 000 NOK.
The 37.84% amount is the final income tax calculated in the annual tax return. It is not an advance tax payment made during the year.
For the AS, the loan amount treated as a dividend is not tax-deductible. If the loan is genuine, it remains on the company's balance sheet as a receivable from the shareholder. For the shareholder, it remains a debt, also for wealth tax purposes.
When is a loan not taxed as a dividend?
The most commonly used exception concerns small, short-term loans. Both conditions must be met at the same time:
- the total debt to the relevant company is less than 100 000 NOK,
- the entire loan is repaid within 60 days of being granted.
An amount of exactly 100 000 NOK does not meet the first condition. The limit cannot be circumvented by making several smaller transfers.
| Situation | Tax consequence |
|---|---|
| A loan of 90 000 NOK repaid after 40 days | The principal is not taxed as a dividend |
| A loan of exactly 100 000 NOK repaid after 30 days | The small-loan exception does not apply |
| A balance of 90 000 NOK increased by another withdrawal to 150 000 NOK | The full 150 000 NOK is taxable |
| Balance remains below 100 000 NOK throughout, but part remains after 60 days | The part unpaid after 60 days is taxable |
If you have several withdrawals, the 60-day period is assessed separately for each of them. Repayments may be allocated first to the oldest debt.
Other statutory exceptions include, among others:
- an ordinary customer receivable arising in the course of the company's business and settled within 30 days,
- credit granted by a financial undertaking, such as a bank,
- an employee loan to a person who directly or indirectly holds no more than 5% of the shares or voting rights in the employer company or a company in the same group.
Under the employee exception, preferential interest may still constitute a taxable employee benefit.
What do interest and later repayment change?
Market-rate interest confirms that the parties take the obligation seriously, but it does not protect the loan principal from being taxed as a dividend. A loan may be interest-bearing, properly secured, and taxed for the shareholder at the same time.
Interest paid by the shareholder is interest income for the AS. For the shareholder, it is subject to the general rules for deducting interest expenses. When a loan qualifies for an exception but is interest-free or carries below-market interest, the interest benefit itself may be taxable.
A later repayment does not reverse the tax charged in the year of payment. If you received a taxable loan of 150 000 NOK in 2026 and repay it in 2027, you will not receive a refund of your 2026 tax as a result.
The actual repayment of a previously taxed loan is treated for tax purposes as a new capital contribution to the company. It increases the tax basis of the shares and the amount of paid-in capital allocated to those shares. This affects the future settlement of a share sale, the shielding deduction, and any return of paid-in capital.
The company may also later approve a dividend and offset it directly against the debt. To the extent of the previously taxed loan, the same amount is then not taxed again. The dividend must actually reduce the debt balance. If you receive the dividend in your private account while the loan remains unchanged, the dividend is subject to ordinary taxation.
If the payment was not a genuine loan from the outset, for example because there was no repayment obligation, repayment capacity, or specific terms, it may be classified as salary or another transfer of value. Reclassification as salary triggers obligations regarding tax withholding, employer's national insurance contributions, and reporting through the a-melding.
How can a loan be granted and settled legally?
Taxation and the legality of a loan are two separate matters. Even a loan granted in breach of company law is taxed as a dividend, and may additionally result in an obligation to repay the money and liability for board members.
Under section 8-7 of the Norwegian Private Limited Liability Companies Act, an AS may grant a loan to a shareholder only within the funds available for dividend distribution. The company must receive adequate, real security, and the board must confirm that sufficient equity and liquidity will remain after the payment.
If the value of the company's consideration exceeds 2.5% of the balance sheet total in the last approved financial statements, the application of section 3-8 of the Private Limited Liability Companies Act must also be assessed. The provision requires, among other things, a formal justification and a board statement. One exemption applies to agreements with a value below 100 000 NOK.
A genuine loan remains a receivable on the AS balance sheet even when it has been taxed for the shareholder as a dividend. Shareholder accounts must be maintained continuously, with the date of each payment and repayment.
A taxable loan must be reported in the Aksjonærregisteroppgaven (the company's report on shares and shareholders). The deadline for information for 2026 is 31 January 2027. From June 2026, the report and corrections for earlier years must be submitted through a compatible accounting system (e.g. Efirma.no) or another end system, rather than directly through Altinn.
Failure to submit a correct report means that the information will not be automatically transferred to the shareholder's skattemelding (tax return). The company may also receive a daily penalty for failing to comply. We discuss how to check shareholder information in more detail in the article Aksjeoppgaven in Norway - what is it and who is required to submit it?
FAQ - frequently asked questions
Summary
- A loan from an AS to a shareholder who is an individual is generally taxed as a dividend as soon as it is paid out. The effective rate in 2026 is 37.84% after taking into account any available shielding deduction.
- The exception requires total debt below 100 000 NOK and full repayment within 60 days. Exceeding the limit causes the entire balance to be taxed.
- A later repayment does not remove the original tax. The loan must also meet company law requirements, be documented, booked, and reported in the Aksjonærregisteroppgaven.
If you need help settling a loan from an AS to an owner or shareholder, call us: +47 21 38 38 21. We help companies in Norway organise their company settlements.
Article author: Marcin - marcin@efirma.no