Requirements for completeness of information

You must familiarise yourself with the requirements regarding the content and scope of the information that must be included in the GloBE Information Return.

The information obligation for reporting entities is regulated by section 8-14, subsection 2 of the Tax Administration Act.

The scope of the reporting obligation depends on a number of factors, including:

  • the group structure
  • the factual circumstances of the group
  • which charging provisions that apply
  • which entities the GloBE Information Return is to cover

The minimum content requirements for the GloBE Information Return depend on which country that have taxing rights. This in turn depends on which entities are located in Norway and which charging provisions apply. Specific requirements apply where the ultimate parent entity of the group is located in Norway. 

If the GloBE Information Return is also submitted on behalf of entities abroad, you must ensure that the return contains the information required for the assessment of global minimum tax and calculation of top-up tax for all entities in the jurisdictions for which you wish to use centralised filing.

If you represent an entity that is part of a domestic group (a group without activities abroad), the GloBE Information Return must contain information on all entities that are part of or connected to the group (constituent entities and joint ventures, as well as their subsidiaries). This applies to completion of General Section, Summary, and Jurisdiction Section.

If the group has entities or subgroups for which separate calculations must be performed, information on those entities or subgroups must be reported in the “Subgroup” elements in the Jurisdiction Section and Summary. Where separate calculations must be performed for an entity or subgroup, the Summary must be repeated in its entirety for the subgroup. 

This applies to:

  • joint ventures and their subsidiaries
  • investment entities and insurance investment entities
  • minority-owned constituent entities and minority-owned subgroups
  • stateless entities

If you represent an entity that is the ultimate parent entity of the group, the GloBE Information Return must include information regarding global minimum tax and calculations of top-up tax for the entire group.

The General Section and the Summary must include information on all entities in the group (constituent entities), as well as all joint ventures and their subsidiaries connected to the group, regardless of where they are located. In addition, the GloBE Information Return must include a Jurisdiction Section for all jurisdictions in which the group operates.

This applies regardless of whether the group uses centralised filing of the GloBE Information Return.

If you represent a Norwegian entity whose ultimate parent entity is located abroud, the GloBE Information Return must, as a minimum, contain information regarding global minimum tax and calculations of top-up tax where Norway has taxing rights under Chapter 2 of the Norwegian Global Minimum Tax Act (and the Model Rules).

This means that the GloBE Information Return must include information on all Norwegian entities in the group, including joint ventures and their subsidiaries located in Norway. In addition, the return must contain information on all countries where the group has entities and where a Norwegian entity is liable to tax under the IIR or UTPRfor the relevant fiscal year. This applies even where the actual calculated top-up tax for the relevant fiscal year in the country is zero.

General Section and Summary must be completed as described for groups with the ultimate parent entity in Norway and must include all entities in or connected to the group (constituent entities and joint ventures, as well as their subsidiaries). In addition, the GloBE Information Return must include a Jurisdiction Section for all jurisdictions and subgroups where Norway has taxing rights. Whether other jurisdictions also have taxing rights is not relevant to the reporting obligation.

If the GloBE Information Return is submitted in Norway on behalf of entities located abroad (centralised filing), it must also include Jurisdiction Sections for all jurisdictions and subgroups for which you wish to use centralised filing.