Norway: Pillar Two global minimum tax implemented in Supplementary Tax Act

Norway implemented the Pillar Two global minimum tax rules in the Supplementary Tax Act, which became effective 1 January 2024.

The Norwegian Ministry of Finance issued a public consultation paper on implementation of the Pillar Two rules in June 2023. 

The new rules entail significant reporting obligations for covered groups, and the first reporting deadline (for the income year 2024) is in June 2026 (i.e., 18 months from the end of the first financial year of the ultimate parent company). From and including the income year 2025, the reporting deadline is 15 months.

• The rules include a national supplementary tax (which is a qualified domestic minimum top-up tax or QDMTT) and an income inclusion rule (IIR). The Ministry proposes implementing an undertaxed profits rule (UTPR) at a later date.
• The rules apply to companies, undertakings, associations, and units that are part of both multinational and national groups (including permanent establishments) with an annual total income of €750 million or more in at least two of the last four financial years before the income year. Included taxes will be, among other things, tax on income, natural resources, and ground rent.
• Entities exempt from the rules generally include public entities, international and non-profit organizations, pension funds, as well as investment funds and entities that invest in real estate if the entity is the ultimate parent company. However, income from exempt entities must be included in determining whether the €750 million threshold is surpassed.
• The rules include a temporary and a permanent safe harbor.

Read an April 2024 report (Norwegian) prepared by the KPMG member firm in Norway