Norway to implement global minimum tax

On 24 November 2023, the Norwegian government submitted a draft bill to the parliament to enforce Norway’s Pillar 2 global minimum tax rules.

On 6 June 2023, the Norwegian Ministry of Finance published a consultation paper on implementing the minimum tax (Pillar Two GloBE Rules) in Norway. The consultation period concluded on 1 August 2023, with the aim to present the final legislation to Parliament before the end of the year.

The global minimum tax rules will apply to international companies with consolidated group revenues exceeding EUR 750 million. The ruleset ensures these groups pay a minimum effective tax rate of 15% on their profits in all countries. The purpose is to protect the tax base from profit shifting and to counteract harmful international tax competition.

The proposal results from long-term international collaboration to change the framework for taxing large, multinational enterprises. The collaboration occurs in the OECD Inclusive Framework, an international cooperative body with over 140 member countries and jurisdictions. The Inclusive Framework has collaborated to reach a consensus on reforming international tax rules to find effective methods to tackle the challenges arising from the digitalization of the economy.

In 2021, a political agreement was reached on a solution consisting of two parts, referred to as pillars. It is pillar 2 of this two-pillar solution, which the government now proposes to implement into Norwegian domestic law to enable the global minimum tax level. The Bill is based on model rules drawn up by the Inclusive Framework.

The Norwegian government is set to introduce global minimum tax rules in 2024.

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