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Norway: Public consultation on introduction of list of non-cooperative tax jurisdictions

Comments are due June 13, 2025.

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June 13, 2025

The Ministry of Finance on May 14, 2025, initiated a public consultation on a proposal to introduce a national list of non-cooperative jurisdictions for tax purposes.

The proposal would implement Article 4 of the EU Securitization Regulation, which requires EEA / EFTA States (Iceland, Liechtenstein and Norway) to create national lists reflecting the EU list of non-cooperative jurisdictions. 

In line with the EU’s listing exercise, the Norwegian list would have two annexes:

  • Annex I for jurisdictions not meeting tax good governance criteria (i.e., tax transparency, fair taxation, and the implementation of OECD anti-BEPS measures)
  • Annex II for those that do not comply with all standards but committed to implementing reforms

The proposal includes legal measures such as prohibiting the establishment of special-purpose vehicles (SPVs) in Annex I jurisdictions and requiring notification for investments in Annex II jurisdictions. The list would be updated following EU revisions.

Comments are due June 13, 2025.

Read a June 2025 report prepared by the KPMG’s EU Tax Centre

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