Global tax reform

OECD and the G20 countries have for some time collaborated on finding a method for dealing with the challenges arising from the digitalisation of the economy.

The global tax reform is among other things, meant to ensure the taxation of large international corporate groups with a minimum rate regardless of where their activities are based. A reporting obligation for affected enterprises will most likely come into effect from 2026. 

In October 2021, a political agreement was reached on changes in the international framework on taxation of large multinational groups.

The new regulations are intended to resolve the following challenges in the present taxation system:

  • rules and regulations that don not regulate the emergence of new digitalised business models​
  • a framework that enables tax planning​
  • unsalutary competition through the provision of tax incentives

A summary of the regulations

The global tax reform, also referred to as “Unified Approach”, consists of two main parts, called pillars.

Pillar 1 – Distribution of company profit

Pillar 1 consists of two parts, where Amount A regulates the distribution of taxation rights to company profits between countries. Under Amount A, some of the profits of large multinational enterprises are redistributed to marked jurisdictions. The regulations apply to multinational groups with a global turnover of 20 billion euros and a profitability rate of more than 10 percent.

Amount B will ensure a more streamlined and simplified assessment of arm’s length pricing for baseline distribution and marketing transactions.

Pillar 2 – Minimum taxation

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Pillar 2 consists of the GloBE rules and the Subject to Tax Rule (STTR).

GloBE rules regulate the global minimum taxation for large multinational groups. The rules are meant to ensure that affected groups are taxed at an effective rate of minimum 15 percent by calculating a top up tax equivalent to the difference between the effective tax rate and 15 percent. ​

The calculated top up tax is based on three different sets of rules:

  • Qualified Domestic Minimum Top up Tax (QDMTT)
  • The Income Inclusion Rule (IIR) means that the calculated top up tax is taxed in the group based on a “top-down” approach, subject to the ownership structure of the low taxed enterprise.
  • The Undertaxed Payment Rule (UTPR) is intended to ensure a minimum taxation of 15 percent in cases where the top up tax is not taxed according to the main rule.

The regulations apply to groups with a global turnover of 750 million euros.

International processes and legislative work in Norway

An international convention on the regulation of Amount A under Pillar 1 by the OECD Inclusive Framework is in progress. It is expected that the convention is completed and opened for signing by states during the second half of 2023. The implementation of the regulations into Norwegian law depends on the further progress and development internationally. It is therefore not yet clear when the regulations linked to Pillar 1 Amount A will come into force in Norway.

A global minimum tax rate according to Pillar 2 depends on the establishment of domestic regulations in each jurisdiction in line with the agreed model rules. 

The Norwegian Ministry of Finance published a draft legislation for the implementation of minimum taxation on 6 June 2023. The draft includes regulation for income inclusion (IIR) and domestic minimum top up tax (QDMTT). The Ministry of Finance intends to revisit proposals for implementation of the UTPR at a later date. In the public consultation notice issued on the matter, the Ministry of Finance proposes that the legal framework for the top up tax will be implemented and take effect from the 2024 income year.

Read the consultation paper and answers at regjeringen.no (in Norwegian only).

OECD has reached a consensus with regards to the framing of the Subject to Tax Rule (STTR) under Pillar 2 and the framework for its implementation. STTR enables developing countries to update bilateral tax treaties in order to impose source taxation on specific intra-group payments subject to low taxation.

Follow the updates from OECD at oecd.org.

Reporting

Reporting obligation

Affected groups must report in the following way: 

Tax return for tax supplement

  • According to the consultation paper, the regulations on top up tax will be treated as a separate tax regime with its own separate tax return.
  • Entities tax liable for a top up tax shall not include the top up tax amount in their regular tax return but file a separate top up tax return.

Separate information return (Globe Information Return)

  • Groups covered by the regulations will be obliged to submit a separate information return, called a Globe Information Return(PDF).
  • The information return forms the basis for calculations related to the regulations and entails a comprehensive reporting obligation.
  • There is currently an ongoing extensive process internationally to implement mechanisms and systems for correct and uniform reporting.  

Reporting deadline

In the regulations’ draft, the reporting deadline is set to 18 months from the end of the first fiscal year a group comes within the scope of the regulations for top up tax, and, after the first year, to 15 months. 

According to the estimated timeline, the first reporting for Pillar 2 is expected to be in June 2026. 

Further information