The consultation addresses deferred and cross-border taxes, pass-through entities, hybrid arrangements, securitisation entities and technical corrections.
The Norwegian government has announced a public consultation regarding the changes to the Supplementary Tax Act, enacted in January 2024 to implement the Pillar Two global minimum tax.
This includes updates to align Norwegian rules with the Inclusive Framework’s guidelines from June 2024 to January 2025, addressing deferred and cross-border taxes, pass-through entities, hybrid arrangements, and securitisation entities. The consultation paper also proposes some technical amendments, which are corrections. The changes are proposed for the 2024 income year.
The deadline to submit comments is set for 4 August 2025.
Earlier, on 12 January 2024, Norway announced the Supplementary Tax Act in the Official Gazette, outlining the implementation of the Pillar Two global minimum tax. It introduces the income inclusion rule (IIR) to ensure a minimum 15% tax for MNE groups with annual consolidated revenue of at least EUR 750 million. However, it does not include an undertaxed payment/profit rule (UTPR). The Act applies to financial years starting on or after 31 December 2023.
Along with the Supplementary Tax Act, Norway published updates to the Tax Administration Act and the Tax Payment Act in the Official Gazette. The Supplementary Tax Act implemented the Pillar Two global minimum tax.
Before that, on 24 November 2023, the Norwegian government submitted a draft bill to parliament to enforce Norway’s global minimum tax rules under Pillar 2.
