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Norway: Consultation on Pillar Two safe harbour amendments

Proposed to apply from income year 2026 and comments due by August 3, 2026

July 14, 2026

The Norwegian Ministry of Finance on June 4, 2026, launched a public consultation proposing amendments to the Supplementary Tax Act and Supplementary Tax Regulation to align Norway’s Pillar Two rules with the OECD Inclusive Framework administrative guidance.

The proposal includes new safe harbour rules, simplified top-up tax calculations, and related technical amendments, with most changes proposed to apply from income year 2026. Comments are due by August 3, 2026.


For more information, contact a KPMG tax professional in Norway:

Camilla Fingarsen | camilla.fingarsen@kpmg.no

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