Transfer pricing in Norway

Transfer pricing in Norway at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline Contemporaneous
Submission deadline upon request 45 days
Annual update required Yes
Official language requirements Norwegian, Swedish, Danish and English
Potential impact of penalties Up to 30% of the tax adjustment

 

Norwegian tax law

Rules for transfer pricing in Norway are based upon:

  • General Tax Act section 13-1

OECD

Norway follows the OECD Transfer Pricing Guidelines.

Methods

Accepted methods  

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method
  • the profit split method
  • the transactional net margin method
  • other methods that provide an arm’s length result

Priority of methods  

Rules for transfer pricing in Norway do not prescribe any priority of methods. However, the traditional methods are generally preferred over the transactional methods

Documentation requirements

  • Key financial figures on all transaction parties to the Norwegian entity
  • Description of how the transfer price on a transaction is actually computed

The level of detail required depends on the complexity of the transaction, and in particular, if the transaction is of high value, intangibles are involved, and/or there may be a tax motivation for pricing the transaction on non-arm’s length conditions.

Language

  • Norwegian
  • Swedish
  • Danish
  • English

Requirements to prepare documentation annually  

Rules for transfer pricing in Norway prescribe that documentation should be prepared contemporaneously.  

Submission deadline upon request by tax authorities

Rules for transfer pricing in Norway prescribe that documentation should be provided to the tax authorities 45 days after a request for documentation has been made.

Advance Pricing Agreements

General  

Rules for transfer pricing in Norway generally do not provide Advance Pricing Agreements (APA) oppertunities, unless it is for the pricing of natural gas.

Terms  

Rules for transfer pricing in Norway do not provide regulations for terms for natural gas APA’s.

Penalties

The transfer pricing penalty, for failing to comply with the Norwegian transfer pricing documentation requirements, is 30% of the tax adjustments.

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