GloBE Country Guide: Norway

Summary

Status	Enacted Law
Law	On June 16, 2025, Norway’s Ministry of Finance opened a consultation on a draft Bill to amend its Minimum Tax Law to implement the OECD’s June 2024 and January 2025 Administrative Guidance. This was enacted as Law 2025-12-22-123 of December 22, 2025. On June 19, 2024, the Norwegian Ministry of Finance initiated a consultation on the introduction of the UTPR. On October 7, the Norwegian government issued the proposal to introduce the UTPR. This was enacted as Act No. 92 on December 20, 2024. On April 3, 2024, Regulations for the implementation of the GloBE law were issued. The Regulations were amended in August 2024, December 2024 and December 2025. On January 12, 2024, the Norwegian Council of State ratified the Norwegian Parliaments enactment of the Supplementary Tax Act in Legislative Decision 37 (2023-2024) Act No. 1. (see Law-2024-01-12-1 )
Effective Date	Accounting periods beginning on or after January 1, 2024
IIR	Yes (2024)
UTPR	Yes (Financial years beginning after December 31, 2024)
QDMTT	Yes
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour, Transitional UTPR Safe Harbour, QDMTT Safe Harbour and the Simplified Calculation Safe Harbour for NMCEs

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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