On 12 January 2024, Normay announced the Supplementary Tax Act in the Official Gazette, which provides the provisions for implementing the Pillar 2 global minimum tax. This includes the introduction of the Pillar 2 income inclusion rule (IIR) to ensure a minimum tax level of 15% for MNE groups with annual consolidated revenue of at least EUR 750 million. The Supplementary Tax Act, however, does not include an undertaxed payment/profit rule (UTPR). The Supplementary Tax Act applies to financial years beginning on or after 31 December 2023.
In addition to the Supplementary Tax Act, Normay also published the amendments to the Tax Administration Act and the Tax Payment Act in the Official Gazette. The Supplementary Tax Act enforces the implementation of the Pillar 2 global minimum tax (supplementary tax).
As per the Act, the notification and return requirements for supplementary tax as well as corresponding payment requirements, go into effect. Related regulations have been published, specifying that the deadline for submitting the supplementary tax notification is 15 months after the end of the financial year. However, this deadline is extended to 18 months for the first financial year. The supplementary tax return is due one month after the notification deadline, while the payment for supplementary tax should be made within three weeks after the supplementary tax return deadline. The related regulations and amendments went into effect on 1 January 2024.
On 24 November 2023, the Norwegian government submitted a draft bill to the parliament to enforce Norway’s Pillar 2 global minimum tax rules.
