Norway, an EEA and OECD member, complies with Country-by-Country reporting rules under OECD’s BEPS Action Plan 13, ensuring comprehensive documentation requirements.
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.
Entities are considered associated if they share 50% or more ownership or control, including various structures and family relations.
Norwegian firms can adopt EU Transfer Pricing Documentation concepts for internal pricing, as long as they meet specific regulations.
Unilateral APAs are rare in Norway, except for gas transactions. Bilateral APAs are feasible based on general provisions in tax treaties.
Tax authorities prioritize areas like intra-group financing, services, TNMM/data base studies, and restructurings.
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.
Norwegian tax authorities accept various methods outlined in OECD Guidelines, with traditional transactional methods preferred.
Transfer pricing documentation must be retained for 10 years.
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.