On 6 June 2023, the Norwegian Ministry of Finance published a consultation paper on the implementation of the minimum tax (Pillar Two GloBE Rules) in Norway.
The draft legislation follows closely the OECD Model Rules and reflects the latest guidance, including aspects of the Commentary, the OECD Safe Harbors Guidelines, and the Administrative Guidance. The top-up tax would apply to large domestic groups and multinationals with consolidated revenues of at least €750 million in two of the last four years.
The draft law incorporates an Income Inclusion Rule (IIR) and qualified domestic minimum top-up tax (QDMTT), but it does not encompass any provisions for an Under-Taxed Profits Rule (UTPR) which intends to revisit the UTPR at a later stage. In the initial phase until 2028, in accordance with the GloBE Implementation Framework, the draft law does not introduce any new specific penalty rules or fines. However, existing penalty rules, similar to those governing corporate income tax, will still be applicable, and the tax authorities will actively monitor instances of non-filing and evasion of top-up taxes.
The consultation period will end on 1 August 2023, with the objective of submitting the final legislation to the Parliament before the end of the year.
