Norway

Implementation of Pillar Two in Norway

The Norwegian Act for the Pillar Two Income Inclusion Rule (IIR) and Domestic Minimum Top-up Tax (DMTT) was implemented from 1 January 2024. The Act more or less ’mirrors‘ the Organisation for Economic Co-operation and Development (OECD) model rules. The Undertaxed Profits Rule (UTPR) is implemented in Norwegian legislation from 1 January 2025.

Notification for top-up tax – GIR (Global Information Return)

The GIR must be submitted electronically in XML format and contains information on, and calculations of, top-up tax for all jurisdictions in which the group is established. The return must be filed regardless of whether the group is actually liable to pay top-up tax.

The filing deadline for the GIR is 15 months after the end of the financial year. However, for the 2024 income year (the transitional year), the deadline has been extended to 18 months. Accordingly, for groups with a financial year ending on 31 December 2024, the GIR filing deadline was 30 June 2026.

Tax reform

The Government has appointed a broadly composed tax commission to provide input on changes to the tax system and help lay out the groundwork for a broad political tax settlement. The commission presented its report on 24 June 2026. The proposal will form part of the further political process, with the Government having announced a white paper on tax reform during 2027. The aim is to create a more predictable and competitive tax system that can endure over time and across changes of government.