{"id":19227,"date":"2023-11-29T15:49:19","date_gmt":"2023-11-29T14:49:19","guid":{"rendered":"https:\/\/wiersholm.no\/?post_type=newsletter&p=19227"},"modified":"2025-03-13T13:43:29","modified_gmt":"2025-03-13T12:43:29","slug":"the-norwegian-government-has-proposed-to-implement-global-minimum-tax-rules-in-norway","status":"publish","type":"newsletter","link":"https:\/\/wiersholm.no\/en\/newsletters\/the-norwegian-government-has-proposed-to-implement-global-minimum-tax-rules-in-norway\/","title":{"rendered":"The Norwegian Government has proposed to implement global minimum tax rules in Norway"},"content":{"rendered":"

The Norwegian Government has proposed to implement global minimum tax rules in Norway<\/h1>\n\n\n
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On 24 November 2023 the Norwegian Government put forward a bill to the Norwegian Parliament to implement internationally agreed 15% global minimum tax rules in Norway. The purpose of the global minimum tax rules is to protect the tax base from profit shifting and to counteract international tax competition.<\/p>\n\n

Tax and Duties<\/a><\/div><\/div>\n\n\n

The bill is available here (in Norwegian only): Prop. 29 LS (2023-2024, Lov om suppleringsskatt p\u00e5 underbeskattet inntekt i konsern (suppleringsskatteloven))<\/a><\/p>\n\n\n\n

The proposed Norwegian global minimum tax rules are largely in adherence with the OECD global minimum tax model rules (the Global Anti-Base Erosion Model Rules)<\/a>. The OECD global minimum tax model rules consist of two charging provisions: the Income Inclusion Rule and the Undertaxed Payment Rule, through which an additional amount of tax called a \u201ctop-up tax\u201d shall be collected when the effective tax rate for a multinational group in a jurisdiction is below 15%. Under the Income Inclusion Rule the starting point is that the ultimate parent entity in the group has an obligation to pay the top-up tax calculated for the group\u2019s low tax entities in a jurisdiction (if any). The Under Taxed Payment Rule acts as a backstop to the Income Inclusion Rule, applying only in specific circumstances where the top-up tax calculated for a jurisdiction is not brought into charge under an Income Inclusion Rule. In addition, the OECD global minimum tax model rules provide that jurisdictions may opt to implement a Qualifying Domestic Minimum Top-up Tax, which allows the top-up tax calculated to be charged by the jurisdiction where the low-level taxation occurred.<\/p>\n\n\n\n

The most important proposals in the bill to implement global minimum tax rules in Norway are as follows:<\/p>\n\n\n\n