In 2013 OECD and G20 countries adopted a common Action Plan on Base Erosion and Profit Shifting that identified 15 actions to combat BEPS.
Action 13 in the Action Plan contains revised standards for transfer pricing and implementation of country-by-country reporting for multinational enterprises with a consolidated revenue of more than NOK 6,5 billion. The country-by-country report is to be filed by the ultimate parent entity of an MNE group.
The report will contain aggregate information including distribution of revenue and tax in the countries in which they do business, as well as a description of the financial acitivity in all businesses (constituent entities) in the multinational enterprise.
Change in the law
The Norwegian Ministry of Finance has followed up the Action Plan by proposing a change in the law that was accepted by the Norwegian parliament, the Storting, in November 2016. According to the Tax Administration Act the MNEs shall file a country-by-country report for the first time in 2017 with information regarding the fiscal year of 2016. The reports may be exchanged with other competent tax administrations across national borders.
Any Norwegian entity of an MNE group must notify the Norwegian Tax Administration of the identity and tax residence of the reporting entity. This notification will be integrated with the tax return, and Norwegian entities have to fill in required CbCR (notification) information about the fiscal year 2016 in the tax return before May 31th 2017.
There are two new fields in the tax return for this purpose.