Tax Administration Act § 8-13 in Norway

Section 8-13 of the Norwegian Tax Administration Act (skatteforvaltningsloven) concerns the obligation to submit a notification for registration regarding value added tax (VAT, merverdiavgift) and special taxes (særavgifter). The provision states:

“Den som skal registreres for merverdiavgift eller særavgifter, skal levere melding om dette til skattemyndighetene.”
(Those who are required to register for VAT or special taxes must submit a notification of this to the tax authorities.)

This means that any entity or individual who meets the criteria for registration under Norwegian VAT or special tax rules must actively notify the tax authorities by submitting a registration notification.

Regulatory Details

The corresponding regulation, § 8-13 in the Tax Administration Regulations (skatteforvaltningsforskriften), further specifies the requirements for the registration notification, including deadlines and the information that must be provided.

Key Points:

The obligation applies to anyone who, according to the law, must register for VAT or special taxes.
The notification must be submitted to the Norwegian Tax Administration (Skatteetaten).
The regulation ensures that the tax authorities are informed when a business or individual becomes liable for VAT or special taxes, enabling correct tax assessment and compliance.

Related Context

This section is part of Chapter 8 of the Tax Administration Act, which deals with the general duty to provide information for tax purposes. The notification requirement under § 8-13 is a fundamental part of ensuring that all taxable entities are properly registered and fulfill their tax obligations.

Summary Table

Section	Topic	Main Requirement
§ 8-13	Registration for VAT and special taxes	Submit notification to tax authorities if registration is required

References to Legal Texts

This provision is administrative and procedural, ensuring that the tax authorities are able to monitor and enforce compliance with VAT and special tax registration requirements in Norway.

Country by Country Reporting

The relationship between Tax Administration Act § 8-13 and Country-by-Country (CbC) Reporting in Norway lies in their shared focus on compliance and transparency, though they address distinct aspects of tax obligations. Here’s a breakdown:

Tax Administration Act § 8-13

Scope: Requires entities to notify the Norwegian Tax Administration (Skatteetaten) when registration for VAT or special taxes is mandatory.
Purpose: Ensures the tax authorities are informed of taxable activities for accurate assessment and enforcement.

CbC Reporting Requirements

CbC Reporting, implemented under BEPS Action 13, applies to multinational enterprises (MNEs) with consolidated revenue exceeding NOK 6.5 billion (≈€750 million). Key features:

Deadlines: Reports are due by 31 December of the year following the relevant fiscal year (or 12 months after a non-standard fiscal year ends).
Content: Includes aggregated financial data for all jurisdictions where the MNE operates, aligned with OECD standards.
Notification Obligation: Norwegian entities must declare the identity and tax residence of the reporting entity in their annual tax return.

Relationship Between § 8-13 and CbC Reporting

Distinct Legal Frameworks:
- § 8-13 governs VAT/special tax registration, while CbC Reporting is mandated under transfer pricing regulations (e.g., 2016 legislation implementing BEPS Action 13).
- CbC obligations derive from international agreements (e.g., the OECD’s CbC MCAA), not § 8-13.
Shared Compliance Principles:
- Both require proactive disclosure to Skatteetaten:
  - § 8-13: Registration for VAT/special taxes.
  - CbC: Annual reporting of global financial data and entity details.
- Non-compliance with either may trigger general tax penalties (e.g., fines up to 40% of avoided tax).
Procedural Overlap:
- CbC notifications (e.g., identifying the reporting entity) are integrated into annual tax returns, while § 8-13 registrations are standalone submissions.
- Both leverage Norway’s digital platforms (e.g., Altinn) for submissions.

Summary Table

Aspect	Tax Administration Act § 8-13	CbC Reporting
Legal Basis	Domestic VAT/special tax rules	BEPS Action 13, OECD guidelines, and 2016 legislation
Scope	VAT/special tax registration	Global financial data of MNEs (revenue > NOK 6.5B)
Submission	Direct notification to Skatteetaten	XML file via Altinn portal
Penalties	General tax sanctions	General tax sanctions (no specific CbC penalties)

Key Takeaway

While § 8-13 and CbC Reporting address different tax obligations, both emphasize Norway’s commitment to transparency and regulatory compliance. CbC Reporting operates under a specialized international framework, whereas § 8-13 is a domestic procedural requirement for VAT/special taxes. Entities subject to both must adhere to distinct processes but share the overarching goal of ensuring tax authorities have accurate, timely information.