Norway: Transfer pricing documentation, country-by-country reporting

Norway: Transfer pricing, country-by-country reporting

A political agreement on future tax amendments has been reached, and included in the agreement are proposed measures for country-by-country reporting that generally are in line with the final recommendations under OECD’s base erosion and profit shifting (BEPS) Action 13 relating to transfer pricing documentation and country-by-country reporting.

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Preliminary discussions on tax reform were finalised in Norway’s Parliament in early May 2016 when an agreement among six of the political parties was reached. The parties agreed to 17 “action points” for the direction of the future tax changes. Among the proposals in the agreement are measures for:

  • A reduction of the corporate tax rate to 23% by 2018
  • An extension of the earnings stripping rules, with application of the rules to all interest payments (and not just interest on related-party loans)
  • Implementation of the proposed actions recommended by the OECD in the base erosion and profit shifting (BEPS) project

KPMG observation

The agreement is a result of extended political bargaining, and in line with the tradition of cross-party consensus on tax reform. Tax professionals, therefore, expect that future work on tax reform proposals would follow or be in line with the agreement, and that any changes would be stable regardless of whether there is a change of government after the general election in 2017. More detailed information on the development of the tax reform is expected once the Committee for Financial Affairs issues its review of the tax reform later this year.


Read a more detailed May 2016 report about the proposals in the political agreement. 


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

Per Daniel Nyberg | +47 40639265 |

Thor Leegaard | +47 40639183|

Marius Aanstad | +47 40639551|

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