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The Norwegian government has sent draft legislation to implement the global minimum tax in Norway on public consultation.
In Brief:
- The consultation paper proposes implementation of an IIR and a domestic minimum top-up tax from fiscal year 2024
- The rules are proposed to apply to both multinational groups as well as large-scale domestic groups
- The public consultation is open until 1 August 2023
This week the Norwegian Ministry of Finance finally published a consultation paper on the implementation of a global minimum tax in Norwegian law. The proposal is closely aligned with the OECD’s model rules on global minimum tax of 15%. In line with the EU Directive, the Norwegian rules will apply to both multinational groups and large-scale domestic groups with a global annual turnover of MEUR 750 or more.
The length of the public consultation document reflects the complexity of the rules. As expected, it is proposed that Norway implements the Income Inclusion Rule (IIR) and a Domestic Minimum Top-Up Tax. It is suggested that the rules will be included in a new chapter 20 in the Norwegian Tax Act with effect for fiscal year2024. This timeline corresponds with the EU Directive and many other countries.
The proposal document does not include an Undertaxed Payment Rule (UTPR), which is the “backstop rule” in OECD’s model rules. The consultation document mentions that the Ministry of Finance will return with a proposal for implementation of the UTPR at a later stage. Considering the timeline in the EU Directive it can be expected that also Norway will implement this rule from 2025.
The consultation paper includes safe harbour rules which are in line with the OECD’s Transitional Safe Harbour Rules.
The consultation paper also contains a number of proposals related to the administrative implementation of the rules, including rules regarding GloBE information return, domestic tax return, tax assessment, administrative appeals, and administrative and penal reactions, etc.
The public consultation is open until 1 August 2023.
Authors:
- Johannes Beck, Senior Manager, Mobile: + 47 41 000 365
- Ingebjørg Brekka, Senior Manager, Mobile: +47 95 21 56 02
- Johanne Heggheim, Manager, Mobile: +47 95 97 94 27
Summary
This week the Norwegian Ministry of Finance finally published a consultation paper on the implementation of a global minimum tax in Norwegian law. It is suggested that the rules will be included in a new chapter 20 in the Norwegian Taxation Tax Act with effect for fiscal year 2024. The public consultation is open until 1 August 2023.