Norway has fully adopted the OECD’s Base Erosion and Profit Shifting (BEPS) Action 13 recommendations regarding Country-by-Country Reporting (CbCR). These regulations aim to improve transparency in corporate tax practices and ensure profits are taxed where economic activities take place.

This guide outlines the CbCR obligations for multinational enterprise (MNE) groups with operations in Norway, including filing thresholds, deadlines, and enforcement provisions.

Regulatory Framework

• Authority: Norwegian Tax Administration (Skatteetaten)
• Legislation:
  • Tax Administration Act § 8-13
  • Tax Administration Regulations § 8-13-1 to § 8-13-8
  • Implementation of OECD guidance and EU Directive 2016/881
• International Engagement:
  • Norway is a signatory to the OECD Multilateral Competent Authority Agreement (MCAA)
  • Member of the Inclusive Framework on BEPS

CbCR Filing Requirements

• Who Must File:
  • Norwegian-resident ultimate parent entities (UPEs) of MNE groups with annual consolidated revenue of NOK 7.5 billion or more in the previous fiscal year
  • Constituent entities in Norway must file locally in specific situations, including when the UPE is not required to file in its jurisdiction
• CbCR Notification:
  • Required annually by all Norwegian entities of an MNE group
  • Must declare whether they are the reporting entity or identify the reporting entity and its jurisdiction
  • Deadline: no later than the end of the fiscal year
• CbCR Submission:
  • Due within 12 months after the end of the reporting fiscal year
  • Filed electronically via the Altinn platform using OECD-compliant XML schema

Penalties for Non-Compliance

• Failure to comply may lead to:
  • Daily coercive fines (tvangsmulkt)
  • Additional enforcement actions under the Tax Administration Act

Important Considerations

• CbCR data is exchanged automatically with other jurisdictions under the MCAA
• Consistency across Master File, Local File, and CbC report is required
• Norway follows a high compliance standard aligned with OECD practices

Useful Resources

• Norwegian Tax Administration (CbCR page): https://www.skatteetaten.no/en/business-and-organisation/reporting-and-industries/country-by-country-reporting/
• Altinn Filing Portal: https://www.altinn.no
• OECD CbCR Portal: https://www.oecd.org/tax/beps/country-by-country-reporting.htm