Aquaculture and ground rent

Guide to records extracted from the Tax Administration help text.

Aquaculture activities and ground rent

The company’s share of maximum allowed biomass before base deduction
The company states its share of the total maximum allowed biomass for all companies that are included in the allocation of the base deduction. The share must correspond to the company’s own maximum allowed biomass.

The company’s share of base deduction
Positive resource rent income is reduced with a base deduction. The reduction happens after any coordination of resource rent income in groups. For the income year 2024, the base deduction is assessed to NOK 70 million. When calculating resource rent income, the base deduction must be adjusted downwards with the tax rate for general income, which amounts to NOK 54.6 million for the income year 2024. The base deduction can only be deducted from positive resource rent income.

The base deduction can only be deducted once on group level. See an extended definition of groups in section 19-3 of the Taxation Act. The base deduction is allocated proportionally based on the maximum allowed biomass per company. An unused base deduction cannot be carried forward to later years. Nor can an unused base deduction in one company be transferred to or coordinated with another company in the group.

Negative resource rent tax upon discontinuation
The tax value of negative resource rent income upon discontinuation can be claimed as payment. Payments cannot be claimed in other circumstances where negative resource rent income arises. It is not a condition for payment that negative resource rent income is offset against positive resource rent income from other group companies.

Own production fee
The company can claim deductions in the resource rent tax for production fees on the production of fish, assessed according to the Excise Tax Act. The resource rent tax cannot be negative as the result of deducting a production fee. A production fee that has not been deducted cannot be deducted in a future income year. For taxpayers liable for resource rent tax, the production fee cannot be deducted from the ordinary income.

An unused production fee can be transferred between companies in a group. The transfer right applies to private limited companies and equivalent companies and organisations that are comprised by the rules in chapter 19 of the Taxation Act. The conditions set out in section 10-4 of the Taxation Act to grant and receive group contributions must be fulfilled. An unused production fee in a company in a group is only deductible in the assessed resource rent tax of another company in the group.

Granted production fee to another company
If the company has granted a production fee to another company in the group, the amount is entered here. You must also provide information about the company that has received the production fee.

Received production fee from another company
If the company claims a deduction for a production fee in another company in the group, the amount is entered here. You must also provide information about the company that has transferred the production fee.

Granted resource rent income to another company
If the company has granted resource rent income to another company in the group, the amount is entered here. You must also provide information about the company that has received the resource rent income.

Received resource rent income from another company
If the company has received resource rent income from another company in the group, the amount is entered here. You must also provide information about the company that has granted the resource rent income.

Income in gross resource rent income

The pen-side market value of sold fish multiplied by the slaughter volume - assessed by the company
Annual gross resource rent income must be set to the pen-side market value of sold salmon, trout and rainbow trout multiplied by the slaughter volume. The sales income is considered as gained when the fish passes the edge of the pen. If the fish is not sold at the edge of the pen, for example, because the fish is first sold to an external party after transport, slaughter, or preparation, the company must assess the pen-side market value for the 2024 income year itself.

It must be adjusted for added value after the fish passes the edge of the pen so that the increase in value from activities after the sea phase is not included in the resource rent income. Increased sales value, for example, as a result of processing and further refinement, sales and marketing activities and transport, should not be included in the tax settlement price at the edge of the pen. When calculating the market value, all circumstances that may have affected the value at the edge of the pen must be taken into consideration.

The pen-side market value of sold fish multiplied by the slaughter volume - assessed by the Price Council
Annual gross resource rent income must be set to the pen-side market value of sold salmon, trout and rainbow trout multiplied by the slaughter volume. The sales income is considered as gained when the fish passes the edge of the pen. If the fish is not sold at the edge of the pen, for example, because the fish is first sold to an external party after transport, slaughter, or preparation, the company must assess the pen-side market value for the 2024 income year itself.

Harvest volume in kg (gutted fish)
The field refers to the number of kilograms of gutted fish. The company can use the conversion as referred to in the Regulations on Special Taxes § 3-24-2.

Income from the sale of live fish in the sea phase
By the sale of live fish in the sea phase, we mean sales where the fish is not taken out of the sea phase in the production process in connection with the sale. This can, among other things, be relevant for joint operation or co-localisation. For fish in the sea phase that is jointly owned by two or more parties, changes in the co-owner position against remuneration are considered as the sale of live fish for the party that has their co-owner share reduced.

The gross income on the sale of live fish in the sea phase is assessed to the market value of the fish at the time of sale.

Gain on divestment of fixed assets
For the divestment of fixed assets that have been recognised directly as a deduction in the resource rent income, the input value must be set to NOK zero, so that the whole sales revenue will be taxed. The remuneration is to be included in the resource rent income for the year of divestment. It is not possible to defer the taxation, for example, by recognising the income on the profit and loss account.

Upon the divestment of fixed assets that have not been recognised directly as an expense, the amount recognised as income must be included in the resource rent income in accordance with the ordinary rules on timing in chapter 14 of the Taxation Act. The calculation of the size of the gain is based on the remuneration upon divestment, less taxable value at the start of the year.

Gain upon the divestment of aquaculture licences is not included in the resource rent income.

In the case of divestment of depreciated fixed assets that are used partly in own activities subject to resource rent tax and partly in other activities, a share of the profit must be included in the resource rent income according to use. When calculating the share, this must be based on the use of the fixed asset in the previous income year.

See separate calculation fields to be used for total divestment of aquaculture activities.

Gain on withdrawal of fixed asset
The same rules that apply to divestment also apply to the calculation of gain in connection with withdrawal of fixed assets. See the field for gain on divestment of fixed assets.

Other income
Here the company may enter any other income subject to resource rent tax that is not included in the above fields. The amount is explained in a separate text field.

Deductions in gross resource rent income

Total operating costs The company can claim deductions for incurred operating costs that regularly follow from the activities that are subject to resource rent tax in the sea phase.

Examples of deductible operating cost are costs for

the purchase or production of hatchery produced fish for stocking
feed
keeping
prevention and treatment of lice, deceases, and similar
salary and other personnel expenses
energy
maintenance
insurance
administration
research and development
environmental measures
recapturing of escaped fish

Deductions are not granted for costs for activities after the sea phase.

Share of remuneration on the purchase of licences, etc.
A deduction is given for 40 percent of the paid remuneration for purchases at the auctions in 2018 and 2020 and the fixed-price distribution in 2020. The deduction is distributed over the income years 2023 to 2027 with equal amounts.

The amount is adjusted downwards with the tax rate for general income, which is 22 percent. This constitutes a deduction of 31.2 percent of paid remuneration (40 x (1-0.22) = 31.2 percent).

The company must not adjust the amount in this field (“Share of remuneration on the purchase of licences, etc.”) downwards by 22 percent. This is because the amount is included in the calculation of the calculated company tax pursuant to section 19-6, subsection 3, of the Taxation Act, and is therefore technically adjusted downwards with the tax rate for general income.

Remuneration for the purchase of live fish in the sea phase
Here you enter the cost price upon the purchase of live fish that were in the sea phase at the time of purchase.

The purchase of live fish in the sea phase can, among other things, be relevant for joint operation or co-localisation. For fish in the sea phase that is jointly owned by two or more parties, changes in the co-owner position against remuneration are considered as the purchase of live fish for the party that has their co-owner share increased.

The cost upon the purchase of live fish in the sea phase is assessed to the market value of the fish at the time of sale.

Property tax
The company can claim a deduction for property tax on floating fish farms at sea.

This applies to physical installations such as, for example,

pens
floating modules
feeding machines
feeding storages
living space
sanitary facilities

A partial deduction is given for facilities that are used partly for activities subject to resource rent tax. The distribution must be carried out in a way that is suitable for providing a correlation between the cost share and use for each activity.

Property tax on other aquaculture facilities that are used for the food fish farming of salmon, trout and rainbow trout in the sea phase is deductible according to the degree the facility is linked to these activities. This applies to, for example, storage buildings onshore that are partly linked to the aquaculture activities that are subject to resource rent tax and partly linked to the taxpayer’s other activities.

Research tax
Research tax, assessed pursuant to the Act of 7 July 2000 no. 68 on tax for research and development in the fisheries and aquaculture industry, is deductible in the resource rent income.

Market tax is not deductible in the resource rent income.

Investment cost (recognised directly as an expense)
The company can deduct the income year’s costs linked to floating fish farms at sea directly in the basis for resource rent tax, if the fixed asset is used exclusively in activities subject to resource rent tax.

This includes physical installations such as

pens floating modules feeding machines feeding storages living spaces sanitary facilities and similar anchor weights and similar for anchoring

The direct deductibility also applies to other physical installations linked to the facility that are exclusively for use in the activities that are subject to resource rent tax.

This includes, for example,
facilities and installations that supply energy to the operation of the fish farming facility
working boats
systems for handling dead fish
water treatment systems
biomass measuring device
other electronic fixed assets that monitor the fish

Information on fixed assets for use in activities subject to resource rent tax must also be given under the topic Fixed assets. See the special guidance for these fields under the topic Fixed assets.

This year’s depreciation of other fixed assets
This year’s depreciation of fixed assets that have not been recognised directly as a deduction can be deducted in the resource rent income pursuant to the ordinary rules of the Taxation Act when they are fully or partly used as input goods in the resource rent activities. This can apply to, for example, well boats that are used to deliver well boat services when the well boats are also used in the activities subject to resource rent tax. The same applies to facilities for hatchery produced fish for stocking and feeding production facilities, where the taxpayer produces hatchery produced fish for stocking or feed, both for own use and for sale.

Information on fixed assets for use in activities subject to resource rent tax must also be given under the topic Fixed assets. See the special guidance for these fields under the topic Fixed assets.

Loss on divestment of fixed assets
Upon the divestment of fixed assets that are to be depreciated in the resource rent income, the rules on deduction upon assessment of ordinary income in chapter 14 of the Taxation Act applies.

Upon the divestment of a fixed asset that have been recognised directly as a deduction in the resource rent income, the opening value is set to NOK zero. A loss upon the divestment of aquaculture licences is not deductible in the resource rent income.

Upon the divestment of depreciable fixed assets that are used partly in activities subject to resource rent tax and partly in other activities, a share of the loss must be deducted in the resource rent income according to use. When calculating the share, this must be based on the use of the fixed asset in the previous income year.

See separate calculation fields to be used for total divestment of aquaculture activities.

Loss on withdrawal of fixed assets
The same rules that apply to divestment apply to the calculation of loss in connection with withdrawal of fixed assets. See the field for loss on divestment of fixed assets.

Other deduction
Here the company may enter any other expenses that they claim a deduction for and that is not included in the above fields. The amount is explained in a separate text field.

Taxes in resource rent

Calculated negative company tax to carry forward
If the calculated company tax is negative, it must be carried forward for deduction in calculated company tax for later income years.

Non-depreciable operating assets, ground rent in aquaculture

Used in activities subject to resource rent tax
Here, the company must provide information about whether the relevant balance group includes fixed assets that are used in aquaculture activities subject to resource rent tax.

Investment cost directly recognised as a cost
Here you enter this year’s investment cost that has been recognised directly as a deduction in the resource rent income in NOK.

Tax value of purchases from related parties
Here the company provides information on continued tax value upon purchases from related parties in the current income year, stated in NOK.

Straight-line depreciated operating assets, ground rent in aquaculture

Investment cost directly recognised as a cost
Here you enter this year’s investment cost that has been recognised directly as a deduction in the resource rent income in NOK.

This year’s depreciation in resource rent income on fixed assets that are depreciated ordinarily
Here you enter this year’s depreciation that is recognised directly as a deduction in the resource rent income in NOK. The amount entered here is the same amount that the company claims a deduction for in the resource rent income, which means the calculated deduction after any allocation between activities subject to resource rent tax and other activities.

Tax value of purchases from related parties
Here the company provides information on continued tax value upon purchases from related parties in the current income year, stated in NOK.

Balance depreciated operating assets, ground rent in aquaculture

Investment cost directly recognised as a cost
Here you enter this year’s investment cost that has been recognised directly as a deduction in the resource rent income in NOK.

Tax value of purchases from related parties
Here the company provides information on continued tax value upon purchases from related parties in the current income year, stated in NOK.

Last modified March 5, 2025