Norway has updated its Supplementary Tax Act to align Pillar Two minimum tax rules with OECD/G20 standards, covering deferred taxes, cross-border allocation, securitization, and anti-avoidance measures, effective from 2023 and 2024 for specific provisions.
Norway’s Council of State has approved Act No. 123 of 22 December 2025 (Prop. 1 LS 2025–2026) amending the Supplementary Tax Act, which establishes the country’s Pillar 2 minimum tax framework for groups meeting the EUR 750 million consolidated revenue threshold.
The proposed amendments in Prop. 1 LS (2025–2026) to the Supplementary Tax Act aim to keep Norway’s implementation of the Pillar 2 global minimum tax fully aligned with the evolving OECD/G20 Inclusive Framework standards. Since the Pillar 2 “Model Rules” follow a common approach, Norway must apply them in a manner that produces outcomes consistent with the international framework.
Reflecting the June 2024 administrative guidance
- Deferred Tax adjustment framework: The guidance clarifies how to track whether deferred tax liabilities are reversed within five years. It introduces specific categories for tracking (individual assets, general ledger accounts, or “composite accounts”) and provides presumptive methods like “First-In, First-Out” or “Last-In, First-Out” to determine which tax liabilities have been settled.
- Cross-border tax allocation: Amendments to the Supplementary Tax Act reflect new methods for allocating taxes between a main office and a permanent establishment (filial) in jurisdictions that allow for “cross-crediting”.
- Securitisation entities: The amendments permit jurisdictions to offer special treatment to securitisation entities to safeguard their creditworthiness. Norway plans to implement this by shifting the tax liability for such entities to another group member based in Norway.
- Flow-through structures: The amendments provide rules for allocating income and tax within complex structures involving transparent entities and reverse hybrids.
Reflecting the January 2025 administrative guidance
- Deferred tax in transition years: The amendments specify which deferred tax assets and liabilities can be included in GloBE calculations at the start of the transition year.
- Anti-avoidance measures: It clarifies that specific government arrangements or choices made after November 30, 2021, that create deferred tax benefits must be excluded if they undermine the intent of the minimum tax.
- Safe harbour adjustments: The amendments clarify how these exclusions affect the Temporary CbCR Safe Harbour rules. Specifically, it introduces a “switch-off rule” where a group may lose access to Qualified Domestic Minimum Top-up Tax (QDMTT) Safe Harbours if a jurisdiction fails to neutralise certain “related benefits.”
Effective date
Amendments to tax allocation and UTPR rules apply to financial years commencing after 31 December 2024, while all other amendments take effect for financial years commencing after 31 December 2023.
Earlier, the Norwegian government announced a public consultation on 16 June 2025 regarding the changes to the Supplementary Tax Act, enacted in January 2024 to implement the Pillar 2 global minimum tax, which ended on 4 August 2025.
