Reporting

The deadline for most MNEs is December 31st in the year after the end of the fiscal year. For companies with deviating annual accounting period starting, for example, July 1st and expiring on June 30th the year after, the deadline is 12 months after the expiry of the fiscal year.

The Country-by-Country-report is to be submitted as an attachment in xml-format to RF-1352 Country-by-Country reporting for multinational enterprises (MNE) via the Altinn-portal.

Test submitting

The Norwegian Tax Administration recommends all reporting entities to take part in test submission before reporting. You may also validate the file format using a validation tool before submitting the file. More on test submission.

Notification obligation

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 Country-by-Country-Report (notification) information about the fiscal year in the tax return before May 31st the year after completion of the accounts.

There are two new fields in the tax return for this purpose.

Background

In 2013 OECD and G20 countries adopted a common Action Plan on Base Erosion and Profit Shifting (BEPS) that identified 15 actions to combat BEPS.

The measure is described in more detail on the OECD website.