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7 December 2016

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Norwegian Parliament Approves CbC Reporting Requirements

The Norwegian parliament has reportedly approved legislation for the introduction of Country-by-Country (CbC) reporting requirements based on BEPS Action 13 guidance. Key aspects of the requirements are summarized as follows:

  • The requirements apply for fiscal years beginning on or after 1 January 2016 for MNE groups meeting a NOK 6.5 billion annual consolidated revenue threshold;
  • Where the ultimate parent entity of the group is not resident in Norway, a resident constituent entity will be required to submit a CbC report if:
    • The parent is not required to submit a CbC report in its jurisdiction of residence;
    • The parent's jurisdiction of residence does not have an agreement in force with Norway for the exchange of CbC reports; or
    • An agreement is in place, but there has been a systemic failure to exchange;
  • Resident entities are required to provide notification of the identity and residence of the reporting entity to the Norwegian tax authorities by the deadline for their tax return (generally by 31 May);
  • When required to be submitted in Norway, the deadline for the CbC report is 12 months after the close of the fiscal year concerned, and the report should be submitted in English.

Note - The secondary reporting requirement for a non-parent entity to file locally will apply for fiscal years beginning on or after 1 January 2017. It is expected, however, that this deferral does not apply for the notification requirement, i.e., the first notification will still be due 31 May 2017.

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