The Tax Commission today presented its report, NOU 2026:9 "Veien mot et bedre og mer forutsigbart skattesystem" (The Road to a Better and More Predictable Tax System). Here is our newsletter with a brief overview of the main points of the proposal.

On 8 October 2025, the Ministry of Finance submitted a consultation memo from the Norwegian Financial Supervisory Authority ("NFSA")  on the implementation of Directive (EU) 2024/927 ("AIFMD II") in Norwegian law. AIFMD II amends both the AIFMD and the UCITS Directive, but the bulk of the changes relate to AIFMD.

In a previous newsletter, we outlined the differences between licensed and registered AIFMs. One major advantage of a full licence is the ability to market funds across borders within the EU/EEA ("passporting"). However, for small and medium-sized managers, there is an alternative: registering the fund as a qualifying venture capital fund (VCF) under the EuVECA Regulation, provided the planned fund strategy aligns with the investment restrictions. Below, we explore who might benefit from this option.

Various types of companies may qualify as alternative investment funds (AIFs). This has practical significance due to the extensive regulations governing the management of AIFs. The Financial Supervisory Authority of Norway (FSAN) actively monitors this area and conducted thematic inspections of entities involved in project financing in the spring of 2023. FSAN's annual report for 2023 also indicates a notable increase in the number of Norwegian AIFs.

Fund establishment requires careful preparation and drafting of relevant documentation. The extent of the documentation varies considerably and depends, among other things, on the intended fund structure, jurisdiction, asset class, type of target investors and the regulatory conditions under which the fund and manager operate.

When do you need to be authorised to manage alternative investment funds? When is it sufficient to be just "registered"? What are the differences?

What type of fund structure should a Norwegian fund manager choose when establishing a new alternative investment fund? This depends, among other factors, on what the fund will invest in, the target investors, the required flexibility for capital contributions and distributions from the fund, the need for confidentiality, etc.

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Partner | Head of Asset Management

Daniel heads the Asset Management practice at Wikborg Rein.

He advises both emerging and established fund managers throughout the entire fund lifecycle – from fund formation and negotiation of agreements, to tax and structuring, co-investments and advice on the underlying acquisition and exit structures.

Daniel has been the responsible partner on several major GP-level transactions, mergers of fund management businesses and similar matters. Transactions in 2025/2026 include DNB's sale of DNB Næringseiendom to Union Gruppen, with settlement in Union shares; the Norwegian State's sale of Argentum's fund management business to EGD Holding; and Never Say Die's acquisition of 70% of the shares in the listed Swedish company H100 Group.

He represents institutional investors both in primary fund investments and in the purchase and sale of fund interests in the secondary market, in Europe and the US, and has advised on dozens of such investments in recent years.

He also regularly advises on the establishment of incentive schemes – both for fund management teams and for the management and employees of underlying portfolio companies.

Daniel is the youngest lawyer ranked on tax in the 2026 edition of Finansavisen's (The Norwegian Financial Daily) lawyer survey (Advokatundersøkelsen), and is recognised as a "Next Generation Partner" on tax by The Legal 500.

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Daniel heads the Asset Management practice at Wikborg Rein. He advises fund managers and investors across asset classes, with a focus on fund formation, negotiations, tax, structuring, transactions and incentive schemes.

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