Norway Pillar Two Filing Guide

What has to be filed in Norway?

Norway’s Pillar Two regime applies to groups with annual consolidated revenue of at least EUR 750 million in at least two of the previous four accounting periods. Norwegian constituent entities within scope have to think about three distinct filings:

Filing timetable

The GIR deadline and the notification deadline are aligned. Both are generally 15 months after the end of the ultimate parent entity’s fiscal year, with an 18-month deadline for the first year the group is in scope. The first Norwegian GIR and the first Norwegian notification are due on 30 June 2026. The Norwegian top-up tax return is due one month later; the first due date published by Skatteetaten is 31 July 2026.

Filing environment

Skatteetaten routes the GIR, notification, validation service, and top-up tax correspondence through its online suppleringsskatt environment. To use the services, the entity must be registered in the Enhetsregisteret and the user must have the right Altinn roles or access package. 

GIR in Norway

Step 1 – Decide whether Norway expects a GIR or only a notification

Every Norwegian constituent entity in scope starts from a GIR filing obligation. If another entity will file a GIR that includes the Norwegian entity, the Norwegian entity must notify Skatteetaten who that filer is and where the GIR will be lodged. But the Norwegian obligation does not disappear if the other filer’s GIR does not contain enough information for Norway to determine the Norwegian top-up tax position. 

Step 2 – Build the XML in English using the OECD schema

The GIR must be prepared in English and filed digitally in XML. Norway’s guidance points filers to the OECD XML Schema and the OECD XML Schema User Guide, and the tax authority also publishes example XML files on GitHub. Skatteetaten recommends both an external XSD validation and use of Norway’s own validation service before filing.

Step 3 – Apply the Norway-specific XML overlay

Norway publishes local rules on what values must be used in the key OECD fields.

Step 4 – Role logic 

Norway uses the OECD role codes, but with clear local consequences:

–GIR401 (UPE): use where the ultimate parent entity files for itself and other group entities and the file is intended for exchange with other jurisdictions.

–GIR402 (DFE): use where a designated filing entity other than the UPE files for all or several group entities and the file is intended for exchange.

–GIR403 (Designated Local Entity): use where a Norwegian entity files for itself and other Norwegian entities and the file is not intended for exchange; Skatteetaten also says this code is used for national groups headed in Norway.

–GIR404 (Constituent Entity): use where the entity is only filing for itself.

The role you choose affects both RecJurCode and the expected scope of the data. The most important filing patterns are:

-Centralized exchange filing: use GIR401 or GIR402; the RecJurCode values in General Section, Summary, Jurisdiction Section, and where relevant UTPR Attribution, must list the jurisdictions that should receive the data and with which Norway has an activated GIR exchange relationship.

-National groups: use GIR403 or GIR404; use only NO in RecJurCode.

-Local filing by Norwegian entities in foreign-headed groups: use GIR403 or GIR404; use only NO in RecJurCode; include Norway and any non-Norwegian jurisdictions or subgroups where Norway has taxing rights.

-Local filing by a Norway-headed multinational group that is not using centralized exchange filing: use GIR403 or GIR404; use only NO in RecJurCode; but the filing must still include Jurisdiction Sections for all countries where the group operates.

Step 5 – Build complete General, Summary, and Jurisdiction Sections