Resource rent tax on aquaculture
Companies that carry out commercial food fish farming of salmon, trout and rainbow trout in the sea must report resource rent income in their tax return.
Resource rent tax on aquaculture is a tax that is meant to ensure that the general public gets a share of the extraordinary return that is generated through the exploitation of jointly owned natural resources.
The regulations entered into force on 1 January 2023. All holders of commercial food fish farming licences for salmon, trout and rainbow trout in the sea, must report resource rent tax on aquaculture in their tax return with the business information from and including the 2023 income year.
For more information, see the guide Skatte-ABC (in Norwegian only) (A-11 Akvakultur (havbruk)).
Who does it apply to?
This applies to all companies that hold a commercial food fish farming licence and are engaged in the farming of salmon, trout, and rainbow trout in the sea.
Please note that all companies holding a commercial food fish farming licence must report the basis in their tax return. This also applies to those who will not come into a position where they pay resource rent tax.
- companies with income from selling salmon, trout and rainbow trout that only hold a licence to farm on land and in the ocean (12 nautical miles from the baseline along the coast)
- companies with income from selling salmon, trout and rainbow trout that only hold a special licence for research, education, viewing, development and production of broodstock and slaughter pens
This is what the company must do
The company must enter relevant income, costs, and other relevant information linked to aquaculture activities in the tax return with the business information.
The company must assess the basis for resource rent tax in their tax return and business information.
- In the business information, net income (before coordination) is calculated and then transferred to the tax return.
- In the tax return, the company must fill in the fields regarding coordination, basic deduction, and production fees. Finally, a positive resource rent tax that the company must pay is calculated, or a negative resource rent income that the company may deduct in a later income year.
Please note that all companies holding a commercial food fish farming licence must report the basis in their tax return. This also applies to those who will not come into a position where they pay resource rent tax.
In addition, the general rules for aquaculture and fish farming apply.
Overview of the contents in the tax return and the Tax Administration's guide to the fields
Calculate resource rent tax on aquaculture
If the company holds ordinary commercial food fish farming licences for farming salmon, trout, and rainbow trout in the sea, it must assess resource rent income linked to the activity in the sea-phase of the production process.
The resource rent tax comes in addition to ordinary income tax.
Basis for the calculation of resource rent tax
| Annual gross resource rent income | |
| - | Deductible expenses |
| - | Negative resource rent income from previous years |
| = | Net income before coordination |
| +/- | Coordination of resource rent income with companies in the same group |
| - | Share of base deduction |
| = | Taxable resource rent income |
| x | 32.1 % |
| = | Assessed resource rent tax |
| - | Production fee |
| = | Resource rent tax to pay |
Negative resource rent income can be carried forward as a deduction in future positive resource rent income in future years. A share of the basic deduction cannot increase the negative resource rent income.
For transactions between companies in a commonality of interest, the companies must consider whether the commonality of interest has affected the transfer price.
Gross income
When the company determines the basis for resource rent tax, they must base it on an annually determined gross income. Gross income is determined based on the market value of the fish at the net cage border and on sold slaughter volume. In addition comes income from the sale of live fish and gains on the sale and withdrawal of fixed assets.
From and including the 2024 income year, agreements regarding financial hedging against fluctuations in the spot market price can be included in gross income. Similarly, losses are tax deductible. This applies to contracts that are entered into with an independent party, reported to the Price Council and intended for price hedging.
If the company also has other types of business activity, the company must divide the income so the part of the income that is included in the resource rent income is equal to the benefit for the resource rent activity.
Price Council on Aquaculture
From 1 July 2024, a Price Council on Aquaculture can determine a binding tax settlement price for salmon, trout, and rainbow trout for use when assessing a gross resource rent income. The tax settlement price is set to the market price that would usually be agreed between two independent parties.
Self-assessment
In cases where the Price Council on Aquaculture has not determined a tax settlement price, the company must assess their own gross income. Income from slaughtered volume must be assessed at market value at the net cage border.
Deductions
The companies get a deduction in gross income for deductible costs, such as costs linked to the sea phase before the net cage border.
The resource rent tax is a cash flow tax. This means that the companies can deduct new costs linked to floating fish farms in the sea in the acquisition year. The condition is that the fixed asset is fully for use in business activity subject to resource rent tax and that it has not been purchased from another company in the same group.
Please note the separate group rules for businesses subject to resource rent tax (see the guide Skatte-ABC (in Norwegian only), chapter A-11-9.7.7) For other income and costs, the ordinary rules on timing in the Taxation Act apply.
- operating expenses
- remuneration for the purchase of live fish
- property tax
- research tax
- share of remuneration on the purchase of licences, etc.
- investment cost (recognised directly as an expense)
- this year's depreciation of fixed assets that have been acquired before 1 January 2023
- this year's depreciation of fixed assets that have been acquired from related parties
- this year’s depreciation of other fixed assets
- loss on divestment of fixed assets
- loss on withdrawal of fixed assets
For costs related to activity linked both to the sea phase and to other activity, the company must divide the income so that the costs and benefits for each type of business activity correspond.
The companies are not entitled to deduct costs linked to activities after the fish has been taken out of the net cages. This could, for example, be sales and marketing costs. The company cannot deduct financing costs.
The company gets a deduction in the resource rent income for a calculated company tax linked to the part of the business activity that is subject to resource rent tax.
The purpose of this deduction is to take into consideration that the relevant income and cost elements have already been taxed or deducted from ordinary income.
Companies with higher costs than gross income will be able to achieve a negative resource rent income in the income year in question. These companies can deduct this year's negative resource rent income in later income years.
If the company is in a tax group with other enterprises subject to resource rent tax, this year's negative resource rent income can be consolidated between these companies. Companies with a negative resource rent income cannot get a positive resource rent income following such consolidation. The share of the basic deduction cannot increase the negative resource rent income.
Each group and the group's related parties receives one basic deduction. Please note the separate group rules for businesses subject to resource rent tax (see the guide Skatte-ABC (in Norwegian only), chapter A-11-9.9.2) This amount is adjusted downwards with the tax rate for ordinary income, so that the effective basic deduction for each group is lower than the nominal basic deduction.
The basic deduction amounts to NOK 70 million (2024). After the adjustment for company tax (22 percent in 2024), the real basic deduction amounts to NOK 54.6 million in 2024.
The companies can deduct the production fee (excise duty) in the assessed resource rent tax.
The unused production fee in one company can be deducted from assessed resource rent tax in another company belonging to the same group. The resource rent tax cannot be negative as the result of deducting a production fee.
Rates
The total tax rate for the companies is comprised by the rate for ordinary income tax and the rate for resource rent tax.
The taxation is carried out by first granting a deduction for the calculated company tax in the resource rent income. To achieve an effective resource rent tax rate of 25 percent, the formal resource rent tax rate is adjusted upwards to 32.1 percent.
| The tax rate for general income (2024): | 22 % |
| + Rate for resource rent tax (2024): | 32.1 % (0.25/(1-0.22) |
| = Total tax rate (2024): | 47 % (after deduction for calculated company tax) |
Specific information if you
If the company, for example, produces food fish under different types of licences on the same location, income and costs must be divided between the activity subject to resource rent tax and the activity not covered by the regulations on resource rent tax.
The income must be divided so that the income and benefits for each type of business activity correspond.
When the company has fixed assets that are used both in activities subject to resource rent tax and in other activity, the company can claim a deduction in the resource rent income for the part that is linked to activity subject to resource rent tax. The deduction for this year's depreciations must be divided so that the costs and benefits for each type of business activity correspond.
When the company sells depreciable fixed assets used partially in activity subject to resource rent tax and partially in other activity, the gain or loss must be divided based on the fixed asset’s benefit to each of the activities. The division must be based on the use of the fixed asset in the previous income year.
Only activities in the sea phase are included in the resource rent tax. Income and costs accrued before or after the sea phase must be excluded.
Many aquaculture actors are organised as integrated companies or groups with activity both before the sea phase, in the sea phase and after the sea phase. These activities could, for example, be production of hatchery fish, transport to slaughter, refining and processing. Pricing of internal purchases and sales must correspond to real market prices, meaning prices that would be agreed between independent parties.
Aquaculture companies can cooperate through joint operations or co-localisation. The company must consider if this activity is carried out at the expense and risk of two or more partners (companies assessed as partnerships) pursuant to the ordinary rules. Businesses assessed as partnerships will also have a reporting obligation regarding resource rent tax on aquaculture.
Contact us
All companies concerned have received a contact person in the Tax Administration.
General questions about resource rent tax on aquaculture, can be sent to us by email.
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