Norway has been a leader in implementing country by country reporting requirements for multinational companies as part of efforts to increase tax transparency and combat profit shifting to low or no-tax jurisdictions. The country by country (CbC) reporting rules require large multinational groups to provide detailed information about their global operations and activities in every country they operate.

Norway first introduced CbC reporting obligations in 2016, following recommendations from the OECD’s Base Erosion and Profit Shifting (BEPS) project. Norwegian parent companies of multinational groups with a consolidated annual revenue over NOK 6.5 billion (approx. €645 million) in the previous fiscal year must submit a CbC report annually to Norwegian tax authorities.

The CbC report includes details on the global allocation of profits, taxes paid, number of employees and business activities for each tax jurisdiction where the multinational group operates. This data gives tax authorities a global overview to assess if there are indications of improper profit shifting between countries.

Norway’s CbC reporting requirements apply to both Norwegian-headquartered multinational groups and foreign-headquartered groups with a Norwegian entity or permanent establishment meeting the revenue threshold. For groups headquartered abroad, a Norwegian subsidiary or permanent establishment may be required to file the CbC report if certain conditions are met.

The CbC report filings are shared between Norway and partner jurisdictions through automatic exchange of information agreements. Over 90 countries have committed to exchanging CbC reports multilaterally. This allows Norwegian tax authorities visibility into Norwegian operations of foreign multinational groups.

While Norway was one of the early adopters of CbC reporting standards, the disclosures remain limited to tax authorities. However, there have been proposals in Norway and other European countries to introduce full public country by country reporting in the future to further tax transparency.

Threshold for Reporting

• Norwegian headquartered multinational groups with annual consolidated revenue exceeding NOK 6.5 billion (approx €645 million) in the previous fiscal year must file a CbC report.
• Foreign headquartered groups with a Norwegian subsidiary or permanent establishment generating revenue over the same NOK 6.5 billion threshold may also need to file in Norway.

Reporting Entities

• For Norwegian parented groups, the ultimate parent company is required to file the CbC report.
• For foreign parented groups, a Norwegian entity may be required to file the report if certain conditions are met, such as the foreign parent’s jurisdiction does not have CbC reporting requirements.

Information Required

The CbC report must include the following details broken down by tax jurisdiction:

• Revenues from unrelated parties
• Revenues from related parties
• Total revenues
• Profit/loss before income tax
• Income tax paid
• Income tax accrued
• Stated capital
• Accumulated earnings
• Number of employees
• Value of tangible assets
• Business activities broken down into categories

Deadlines

• The CbC report covering the preceding fiscal year must be filed no later than 12 months after the last day of that fiscal year.

Notification Requirements

• Norwegian entities of a multinational group must annually notify which entity will be filing the CbC report for the group.
• This notification is due by the last day of the fiscal year concerned.

Penalties

• Failure to file the CbC report can result in penalties.
• Entities may also be penalized for not meeting notification requirements.

The CbC reports are shared between tax authorities of different jurisdictions through automatic exchange of information networks. Groups should ensure consistency across all country filings.