Norway: Country-by-country reporting proposal | KPMG | GLOBAL
Share with your friends

Norway: Country-by-country reporting proposal, public consultation

Norway: Country-by-country reporting proposal

The Norwegian Ministry of Finance published a public consultation paper regarding country-by country reporting for tax purposes. The proposal suggests that multinational groups—when the ultimate parent company is a resident in Norway—would be required to submit country-by country reports. The reporting requirements could also affect foreign group entities that are residents in Norway if certain conditions are met. The public consultation ends 25 January 2016.


Related content

The Norwegian proposal is generally in line with the final report issued in October 2015 under the OECD’s base erosion and profit shifting (BEPS) Action 13, Transfer pricing documentation and country-by-country reporting.

In addition, the proposal follows the 2016 Norwegian state budget and the government’s previous suggestions for tax reform. Read TaxNewsFlash-Europe

Overview of proposed country-by-country reporting rules

With respect to country-by-country reporting, it is proposed that all Norwegian companies of multinational groups with a consolidated turnover of at least NOK 6.5 billion (approximately U.S. $720 million) would be required to file a country-by-country report. The country-by-country report would then, in principle, be made available to all countries where the group operates (i.e., through its subsidiaries and / or permanent establishments). However, a confidentiality provision is suggested—that is, the country-by-country report could only be submitted to tax authorities in other jurisdictions and only when there is an agreement in force pertaining to international law.

If the ultimate parent company of the group is a tax resident in Norway and the reporting threshold is satisfied, the proposal suggests that the country-by-country report would be submitted to the Norwegian tax authorities in the English language.

Furthermore, it is proposed that other subsidiaries in Norway of foreign-based groups would have to submit the country-by-country report if certain conditions are met. These conditions would apply if:

  • The ultimate parent company is not required to file a country-by-country report in the jurisdiction where it is a resident; 
  • The ultimate parent company is a resident in a jurisdiction that has not signed a specific agreement for the automatic exchange of country-by-country reports with Norway; or 
  • There are other measures preventing the automatic exchange of country-by-country reports.

It is proposed that the amendments to Norway’s tax law (known in English as the “Tax Assessment Act”) would be effective for all accounting years starting 1 January or later. Hence, the country-by country report would have to be submitted for the first time before 31 December 2017 for the fiscal year 2016.

KPMG observation

Under the proposed country-by-country reporting measures, multinational groups whose ultimate parent company is a resident in Norway and having a turnover exceeding NOK 6.5 billion need to be ready to file country-by-country reports. According to information provided by the Ministry of Finance, it is expected that about 70 Norwegian groups would be required to submit country-by-country reports. 

Tax professionals in Norway anticipate that the current proposal could be passed by Parliament without significant changes during the spring of 2016.


For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group in Norway.

Per Daniel Nyberg | +47 40639265 | 

Marius Basteviken | +47 4063 9032 | 

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal