Transfer Pricing in Norway

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Norwegian companies and permanent establishments with controlled transactions or dealings have to apply to Norwegian documentation rules.

The documentation rules are set forth in the Tax Administration Act section 4-12 and the Regulations relating to the Documentation of Price Determination for Controlled Transactions and Transfers. The Norwegian Transfer Pricing Documentation Guidelines are not translated to English.

In addition, companies with intercompany are obliged to follow the Regulations relating to the Duty to Specify Controlled Transactions and Accounts Outstanding and complete the form RF-1123. The rules cover both cross-border transactions and transactions between Norwegian companies, etc.

In Norway the arm’s length principle is set forth in the General Tax Act section 13-1 and is in line with the Model Tax Convention article 9 and the OECD’s Transfer Pricing Guidelines. An overview of the General tax conventions between Norway and other states can be found here.

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