Registering a Georgian Individual Entrepreneur and getting Small Business Status is the fast part of this move, and Georgia's 1% rate is real. What decides whether that rate is actually yours is a question Norwegian law asks, not Georgian law: have you genuinely ended Norwegian tax residency under skatteloven's own test, and have you settled what Norway charges on your way out. Norway runs a real trap for anyone who has lived there ten years or more: breaking every tie is not enough on its own, you also have to wait out a three-year tail. This guide works through what Norwegian law actually requires before the 1% is legally yours.
What a self-employed Norwegian actually pays, here and there
Start with the number, because it is the reason anyone reads this far.
A self-employed Norwegian running an enkeltpersonforetak with NOK 800,000 of net business profit pays trygdeavgift, the national insurance contribution, at 10.8% on business income, confirmed on Skatteetaten's own rate page: roughly NOK 86,400. Fellesskatt, the flat 22% general income tax, adds NOK 176,000. Trinnskatt, the progressive bracket tax layered on top, adds a further NOK 28,100 or so at this income level, working through the published 2026 brackets from 1.7% up to 17.8%.
| Norway (enkeltpersonforetak, 2026) | Georgia (IE + Small Business Status) | |
|---|---|---|
| Turnover / net profit | NOK 800,000 | NOK 800,000 |
| Trygdeavgift (national insurance, 10.8%) | ~NOK 86,400 | - |
| Fellesskatt (flat 22%) | ~NOK 176,000 | - |
| Trinnskatt (bracket tax) | ~NOK 28,100 | - |
| Georgian tax (1% of turnover) | - | NOK 8,000 |
| Total | ~NOK 290,500 (~36%) | NOK 8,000 (~1%) |
That gap, roughly 36% against roughly 1%, is the entire reason this guide exists, and exactly why Norwegian law does not let it happen the moment someone books a flight.
Does the 1% actually apply to your income in the first place
Before any of the Norwegian math matters, the 1% has to genuinely apply, which is a Georgian-side question first. Small Business Status taxes Georgian-source income, and for services that generally means work physically performed in Georgia, not work billed through a Georgian registration while sitting in Oslo or Bergen. We cover the mechanics fully in Georgia's 1% tax and the source test in Georgian-source income rules. What changes for a Norwegian national specifically is everything downstream: whether Norway still considers you resident, and what it charges on the way out if it does not.
What Norway does when you leave
Norway's residency test differs sharply depending on how long you lived there before leaving. Someone resident under 10 years can end tax liability from the year after departure, provided they genuinely take up permanent residence abroad. Someone resident 10 years or more faces a stricter version, confirmed by Skatteetaten: tax liability does not cease until the third full income year after the year you took up permanent residence abroad has ended.
If you lived in Norway for 10 years or more before leaving, severing every tie is not enough on its own. You also have to sit out three full income years after the year you left before Norwegian tax liability actually ends, and during that run-off period you cannot spend more than 61 days a year in Norway, and neither you nor your spouse or children can own, rent or otherwise have available a home there. A clean break followed by a long visit home the following year, or a flat kept "just for storage," can reset the clock.
Norway also runs a genuine exit tax on shares, unlike some countries in this cluster that only run a trailing residence rule. Unrealised gains on shares and similar holdings are taxed as if sold the day before you stop being tax resident, but only above a basic allowance, raised from NOK 500,000 to NOK 3,000,000 as part of the 2024 reform. Above that allowance, you can pay the tax immediately, spread it over 12 years without interest, or defer the whole amount for 12 years with interest accruing; taking dividends out of the company in the meantime accelerates it, since 70% of any dividend received counts toward repaying the exit tax first. Moving back to Norway within the 12-year window while still holding the shares extinguishes the liability entirely.
Folketrygden, Norway's national insurance scheme, generally stops covering you once you are genuinely resident abroad and no longer contributing through Norwegian employment or business activity, though voluntary continued membership is available to anyone who was a member for at least three of the last five years, subject to NAV's approval. Norway's CFC regime, NOKUS, reaches Norwegian taxpayers who control 50% or more of a foreign company taxed at less than two-thirds of the equivalent Norwegian rate, confirmed by PwC's Norway tax summary. A Georgian IE is not a company for this purpose, so NOKUS generally does not engage. A Georgian LLC is a company, its 0% tax on retained profit clears the low-tax threshold easily, and Georgia is not in the EEA, so the substance-based exception that protects some EEA structures does not help here either.
Norway and Georgia have had a double taxation treaty since it was signed in 2011, confirmed on Georgia's Ministry of Finance treaty list, giving a tie-breaker to fall back on once residency is actually disputed. Norway does not currently maintain its own list of non-cooperative jurisdictions separate from the EU list, though a national list mirroring the EU one was under public consultation as of 2025. Georgia does not appear on the EU list either way, so there is no blacklist issue here.
The steps, in order
- Work out whether the 10-year rule applies to you. If you were tax resident in Norway for 10 years or more before leaving, plan for a three-year run-off, not an immediate exit.
- Give up Norwegian housing properly, and make sure your spouse or children do not retain a home there either, since that alone can reset the clock during the run-off period.
- Track your days in Norway during the run-off years. Staying under 61 days a year matters as much as the housing test does.
- Value your Norwegian and foreign shareholdings against the NOK 3,000,000 exit-tax allowance before you leave, not after.
- Choose how to handle any exit tax due: pay it immediately, spread it interest-free over 12 years, or defer it with interest, and plan any dividends around the 70% offset rule.
- Register a Georgian Individual Entrepreneur and apply for Small Business Status, either in person or under power of attorney through remote company registration.
- Choose an IE over an LLC if NOKUS exposure is a live concern, since an IE generally sits outside the regime while a Georgian LLC does not.
- Decide whether to keep voluntary folketrygden membership if you were a member for at least three of the last five years, since it does not continue automatically.
Timeline and cost
The Georgian side is fast: an IE with Small Business Status is typically registered within days in person, or two to three weeks under power of attorney. The Norwegian side sets the real pace, and it is genuinely longer than most countries in this cluster if the 10-year rule applies: a three-year run-off before tax liability actually ends, plus whatever time it takes to value shareholdings and decide on an exit-tax payment plan before you leave.
The verdict for a Norwegian national
Georgia works with conditions for a Norwegian national, and the condition depends heavily on how long you lived in Norway before leaving. Under 10 years, the position is comparatively simple: sever residency properly and the 1% is durable fairly quickly. Ten years or more, and the honest answer is that Norway keeps a live claim for three full years after departure regardless of how clean the rest of the break is, and any real shareholdings need an exit-tax decision made before you go, not after a letter arrives.
We'll work through whether the 10-year rule applies to you, what your exit-tax exposure looks like against the NOK 3,000,000 allowance, and whether an IE or an LLC is the right call given NOKUS, before you register anything here. Written summary included.
See what it costs
For the same analysis built for a Swedish departure, see moving from Sweden to Georgia, and for how a treaty tie-breaker actually gets invoked once one exists, see Georgia's double taxation treaties. Our country-by-country guide compares the treaty position and headline trap for every country we cover.
Key takeaways
- A self-employed Norwegian on NOK 800,000 of profit pays roughly 36% all-in at home versus roughly 1% under Georgian Small Business Status.
- Ten or more years of Norwegian residence means a three-year run-off after departure, on top of genuinely severing every tie, not instead of it.
- Norway's exit tax now applies to unrealised share gains above NOK 3,000,000, payable immediately, over 12 interest-free instalments, or deferred 12 years with interest.
- Taking dividends during the deferral period accelerates the exit-tax bill, since 70% of any dividend counts toward repaying it first.
- NOKUS generally does not reach a Georgian IE but can reach a Georgian LLC controlled by Norwegian residents.
- Norway and Georgia have had a tax treaty in force since 2011, and Georgia is not on the EU's non-cooperative list Norway references.
Frequently asked questions
Does moving to Georgia automatically end my Norwegian tax residency?
No. If you lived in Norway under 10 years, genuinely taking up permanent residence abroad ends liability from the year after you leave. If you lived there 10 years or more, liability does not end until three full income years after your departure year have passed, on top of severing every tie.
What is the three-year rule and who does it apply to?
It applies to anyone who was tax resident in Norway for 10 years or more before leaving. Even after giving up housing and family ties in Norway, tax liability continues until the third full income year after the year of departure has ended, provided you also stay under 61 days a year in Norway during that period.
Can I visit Norway during the three-year run-off period?
Only briefly. Norway sets a limit of 61 days per income year during the run-off phase. Exceeding it, or letting a spouse or child keep a home available in Norway during the same period, can reset the clock on the whole test.
What is Norway's exit tax and has it changed recently?
Yes, significantly, as of 2024. Unrealised gains on shares and similar holdings above a NOK 3,000,000 allowance are taxed as if sold the day before residency ends. The tax can be paid immediately, spread interest-free over 12 years, or deferred for 12 years with interest, and moving back to Norway within that window while still holding the shares cancels the liability.
What happens if I take dividends while the exit tax is deferred?
Seventy percent of any dividend you receive during the deferral period is applied against the outstanding exit tax first, rather than being paid out to you freely. This is specifically designed to stop using dividends to strip value out of a company while the exit tax sits unpaid.
Does Norwegian CFC law, NOKUS, reach a Georgian Individual Entrepreneur?
Generally not. NOKUS attributes income from a foreign company controlled by Norwegian residents. A Georgian IE has no separate legal personality, so there is no company for the rule to attach to.
Does the same apply to a Georgian LLC?
No. A Georgian LLC is a company, and if Norwegian residents control 50% or more of it, its 0% tax on retained profit is well below the two-thirds-of-Norwegian-rate threshold that defines low taxation. Georgia is outside the EEA, so the substance-based exception available to some EEA structures does not apply.
What happens to my folketrygden membership if I leave?
It generally stops once you are no longer resident or working in Norway. If you were a member for at least three of the last five years, you can apply for voluntary continued membership, but it requires an active application and NAV's approval rather than continuing by default.
Is there a tax treaty between Norway and Georgia?
Yes, signed in 2011 and in force, which gives a tie-breaker to resolve dual-residency disputes and caps certain withholding rates. It does not switch off the three-year rule or the exit tax, both of which are domestic Norwegian law rather than treaty questions.
Is a Georgian IE or an LLC the better structure for a Norwegian national?
For most solo movers with real NOKUS exposure, the IE is simpler, since it generally sits outside Norway's CFC regime entirely. An LLC can still make sense for other reasons, liability separation or multiple owners among them, but it needs a real look at the NOKUS position first rather than being assumed safe by default.