Norwegian court decision opens major wealth-tax loophole using foreign-held B shares

A landmark judgment from the Borgarting lagmannsrett demonstrates that affluent Norwegians can dramatically lower their wealth-tax burden by relocating non-voting B shares to foreign structures, such as a foundation in Switzerland, while preserving control through A shares that remain in Norway. Under current tax rules, unlisted shares are valued equally per share, so the taxable base can be moved abroad without losing dividend entitlement domestically.

The dispute originated in the Sundt family, where a father transferred the majority of his holdings to his children yet retained decision-making power and drew a large portion of the value as dividends before the company was wound up. Both the district court and the appellate court ruled the arrangement lawful, and the Supreme Court’s appeal panel rejected a challenge. Tax lawyer Hugo Matre of Schjødt warned that the method may be limited if used speculatively, but it does not require owners or heirs to relocate abroad.