Appeal against a decision on global minimum tax
If you've received a decision from the Norwegian Tax Administration, you have the right to appeal.
You can appeal
- a decision on assessed top-up tax
- a decision on the basis for calculating the global minimum tax
- a decision imposing an enforcement fine
- a decision regarding additional tax
- a decision rejecting an appeal
You should not appeal if you want to amend a GloBE Information Return or GloBE Tax Return after it has been submitted. Instead, you must submit a request to amend. If you've received a notice of amendment and disagree with it, you should respond to the notice in My GloBE Tax.
How to appeal a decision
Your appeal must be submitted in writing. You must state the type of decision you're appealing and the reference number of the decision. You’ll find the reference number at the top of . You must also provide a reason for the appeal and specify the changes you are requesting. Any other information and supporting documents that may be relevant to the assessment of the appeal should also be attached.
To be able to submit, the entity you represent must be registered in the Central Coordinating Register for Legal Entities. In addition, you must have a role or access package that grants you the necessary rights.
Roles
Limited signing rights (SISKD)
Accountant with signing rights (A0239)
Responsible auditor (A0237)
Access packages
Business tax
Accountant with signing rights
Auditor in charge
The service "Global minimum tax"
A limited access right that only permits you to validate and submit the GloBE Information Return, the GloBE Notification, the GloBE Tax Return, and to write to us about global minimum tax.
You can find information about roles and rights on Altinn. You must also contact Altinn if you have questions about assigning or delegating roles and rights.
You must submit the appeal within six weeks
The appeal must be submitted within six weeks of receiving the decision.
If the six-week deadline has passed, we'll consider whether we can still process the appeal. When making that assessment, we'll take into account factors such as how much time has passed since the decision was made, how well the case has been documented, how important it is for the entity that the decision is changed, and why the appeal was submitted after the deadline.
If more than one year has passed since the decision was made, we cannot process the appeal as an appeal case.
After you've submitted your appeal
Once you've submitted your appeal, you'll receive a confirmation of receipt. We'll review the appeal and assess whether there are grounds for changing the decision in line with your appeal. If we do not change the decision, we'll forward the case to the Tax Appeals Board, which is the correct appeal body.
Do you need to provide new information about your appeal?
If you've already submitted an appeal and need to provide additional information or have questions, you can log in to My GloBE Tax. There you'll find the confirmation of receipt of your appeal and can write directly to us about the case.
The entity's rights and obligations
You have a right to access the case documents. You can request these through our contact form by selecting "Other questions".
If your appeal is successful, you may be entitled to reimbursement of substantial and necessary costs you've incurred in connection with the appeal. Contact us if you have questions about which costs may be covered.
Even if you've appealed a decision, you must still pay the claim by the ordinary payment deadline. If the claim isn't paid by the deadline, interest on late payment will accrue.
If the appeal concerns iposition of additional tax, you are not required to pay the additional tax while the appeal or court proceedings are ongoing.
You can get help from an authorised representative to appeal on behalf of the entity. An authorised representative can be either an individual or a professional organisation, such as a lawyer. We recommend giving the authorised representative the necessary access rights in Altinn to log in on behalf of the entity.
We recommend submitting your appeal through our website, but you can also send it by post to:
Skatteetaten
Postboks 9200 Grønland
0134 Oslo
Contact us
If you have questions about global minimum tax, you can contact us by logging in to our online portal and write to us.