Norway’s Ministry of Finance has initiated a public consultation on proposed amendments to the Supplementary Tax Act.
As previously noted, Norway announced the Supplementary Tax Act in the Official Gazette on 12 January 2024, 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. The proposed amendments aim to include an Undertaxed Payment/Profit Rule (UTPR) that, pending approval, will be implemented starting from the 2025 income year.
