Mutual agreement procedure (MAP)

If you’re taxed for the same income or capital/wealth in Norway and another country, you can contact the tax authorities in the two countries and request that they decide which country has the right to tax you.

The double taxation may for instance apply to salary income, pension, capital income or wealth.

Mutual agreement procedure (MAP)

A mutual agreement procedure is a process where the authorities in two countries, following a request from you, can agree on how to avoid taxation not in accordance with the tax treaty.

Time limits for requesting a MAP

Each individual tax agreement has its own time limits for requesting a MAP. The time limit is generally three years from the first notification of the action resulting in taxation not in accordance with the treaty.. Please note that for some tax treaties, the time limit is only two years, while other tax treaties have no time limit. It’s therefore important that you check the relevant tax treaty with regard to time limits.

You can request a MAP as soon as you become aware that you've been taxed in both Norway and another country in a way that’s not in accordance with the provisions in the tax treaty.

Normally, this will be when you receive the tax assessment in Norway, or similar information that you’re taxed in another country.

If you’ve also appealed the tax assessment in Norway

You can request a MAP even if you’ve appealed the tax assessment in Norway. If you both request a MAP and appeal the tax assessment, one process will be put on hold until the other process is finished. You can choose which process will be handled first. Read more in the guidelines for MAP, point 10 (pdf). Which of the processes is put on hold must be evaluated individually.

Requirements for the request 

The request must be in writing and can be submitted as a letter, or you can log in to Altinn and send us a message.The request can be in Norwegian, English or any of the Nordic languages. It’s important to state that the request concerns a MAP.

  • your name and national identity number
  • your address, telephone number and e-mail address
  • a contact person, if relevant
  • the relevant income year(s)
  • the country you’re taxed in
  • the income that has not been taxed in accordance with the tax treaty
  • the provision(s) in the tax treaty that has/have been applied incorrectly, why you believe this is incorrect, and the country that has acted incorrectly
  • which tax office abroad you’ve been in contact with
  • pending appeals of your tax assessment in Norway and/or the other country
  • other relevant details
  • a confirmation that you’ve provided all relevant information and that you will assist with further information if required

You must submit the following documentation

  • documentation showing that you’re taxed abroad
  • copy of correspondence with the tax authorities in the other country
  • copy of appeal and decision in any appeal case in Norway and/or the other country
  • other relevant documentation
  • power of attorney for your representative, if relevant

If the documents is in another language than Norwegian, English or any of the Nordic languages. 

Send the request to

Normally, you must send the request to the authorities in the country you think you’re a tax resident in according to the tax treaty.

When you’re a tax resident in Norway:

The request for a MAP can either be submitted by logging in to Altinn and sending us a message, or by posting a letter to:

Skattedirektoratet
Postboks 9200 - Grønland
0134 Oslo

or

Finansdepartementet
Skattelovavdelingen
Postboks 8008 Dep.
0030 Oslo

It is not possible to provide a fixed case processing time. This will vary from case to case.

The case processing time will depend on how much time the authorities in the other country spends on the case and how easy it is for the authorities to come to an agreement.

We must come to an agreement with the authorities in the other country on what is the correct taxation. Some cases can be solved without the authorities in the other country being involved.

When you’re a tax resident abroad:

The request for a MAP must be submitted to the competent authorities in the other country. You’ll normally find the address to which the request for a MAP should be sent under “Map Profiles" on OECD’s homepage. If you cannot find the address there, you can contact the tax authorities in the other country.

Payment of underpaid tax

You do not get an extension for the payment of Norwegian underpaid tax when a case is processed according the rules on mutual agreement procedure. The underpaid tax must be paid within the deadline you’ve received.

More information

You can find more information in the guide for mutual agreement procedure pursuant to tax treaties (MAP).

Here you’ll find an overview of Norway’s tax treaties.