Transfer Pricing
Country Summary

This document summarizes the transfer pricing requirements and regulations in Norway. Norway, an EEA and OECD member state, adheres to Country-by-Country reporting rules aligned with OECD’s BEPS Action Plan 13. The arm’s-length standard for related party transactions is integrated into its General Tax Act, with reference to OECD Transfer Pricing Guidelines. It defines related parties broadly. Companies can prepare transfer pricing documentation following EU Transfer Pricing Documentation (TPD) concepts. The audit focus includes intra-group financing and restructurings. Norway has implemented BEPS Action Plan 13 for country-by-country reporting. Smaller enterprises enjoy exemptions from documentation requirements based on fair value thresholds. Penalty taxes and interest apply to incomplete or incorrect filing.


OECD Influence:

Norway, an EEA and OECD member, complies with Country-by-Country reporting rules under OECD’s BEPS Action Plan 13, ensuring comprehensive documentation requirements.

Regulatory Framework:

Norway upholds the arm’s-length standard for related party transactions within its General Tax Act, with explicit reference to OECD Transfer Pricing Guidelines. Specific legislation addresses the pricing of petroleum for tax purposes.

Related Parties Defined:

Entities are considered associated if they share 50% or more ownership or control, including various structures and family relations.

Transfer Pricing Documentation:

Norwegian firms can adopt EU Transfer Pricing Documentation concepts for internal pricing, as long as they meet specific regulations.

Advance Pricing Agreement (APA):

Unilateral APAs are rare in Norway, except for gas transactions. Bilateral APAs are feasible based on general provisions in tax treaties.

Audit Focus:

Tax authorities prioritize areas like intra-group financing, services, TNMM/data base studies, and restructurings.

Transfer Pricing Documentation Requirements:

Country-by-Country reporting aligns with BEPS Action Plan 13. Smaller, less complex enterprises with transactions under a specific fair value threshold enjoy documentation exemptions.

Choice of Transfer Pricing Method:

Norwegian tax authorities accept various methods outlined in OECD Guidelines, with traditional transactional methods preferred.

Record Keeping:

Transfer pricing documentation must be retained for 10 years.

Penalties and Interest:

Failure to file required documentation may result in penalty taxes. Penalty rates range from 20-60%, with the highest for gross negligence. Late payment of corporation tax will incur interest.

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