Corporate - Significant developments

Last reviewed - 24 August 2021

Delayed filing and payment deadlines due to COVID-19

The general tax filing deadline for corporations for the income year 2020 was 31 May 2021, but due to the COVID-19 situation, corporations could apply for a deferred deadline until 20 August 2021. The deadline for applying for a postponement was 31 May.

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, we see the legislation is as of today 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 rent payments), provisions regarding WHT on interest, royalty and certain rent 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 will be limited by existing Norwegian tax treaties.