Corporate - Significant developments

Last reviewed - 23 December 2021

The Government has proposed fundamental changes to the petroleum tax regime. The proposal implies a shift to a so-called cash-flow tax system. It is suggested that the changes shall be effective from and including the 2022 income year. However, at present the proposed rules have not been adopted.

Proposal for disclosure of tax arrangements is delayed

The report from the special committee to consider the implementation of reporting obligations for tax arrangements, corresponding closely to European Union (EU) Directive 2018/822/EU (DAC 6), was published on 27 June 2019. The consultation deadline was 2 December 2019. The original expectation was for a legislative decision in 2020 with effect from 2021. In light of the uncertainty surrounding the technical details of the legislation, the high implementation costs, and the recent EU reporting extension, the legislation is delayed.

Withholding tax (WHT) on interest, royalties and certain rent payments to related companies in low-tax jurisdictions

From 1 July 2021 (1 October 2021 for lease payments), provisions regarding WHT on interest, royalty and certain lease payments to related companies in low-tax jurisdictions were introduced. The WHT rate is set at 15%. An exemption has been made for payments to low-tax jurisdictions within the EEA, provided that the receiving company is genuinely established and fulfills an overall substance test. The application of WHT on royalties and interest may be limited by existing Norwegian tax treaties.