Do you run a Norwegian branch or subsidiary within a foreign group? If so, you may have Pillar 2 compliance obligations in Norway even if your Norwegian operations are small. In this blog, we explain who is affected, what obligations you have locally, and why you cannot rely on the group handling everything centrally.
The Norwegian Supplementary Tax Act implements the OECD Pillar 2 rules on global minimum taxation into Norwegian law. The goal is simple: Large groups must pay at least 15 percent effective tax in every country they operate in. The rules look at the group as a whole, not the individual legal entity. This means Norwegian branches and subsidiaries can be caught, even if they'd never be covered under traditional Norwegian tax rules.
The rules apply to groups with consolidated revenue exceeding EUR 750 million. It doesn't matter where the parent company is based. If your group has operations in Norway, the Norwegian entity is covered, regardless of how small its share of the group's overall activity may be. The scope extends to all entities consolidated in the group accounts. This means your Norwegian branch can fall within the regime even if all decisions are made outside Norway.
At the core of the regime is the calculation of the effective tax rate per country. The tax authorities assess the ratio between adjusted taxes and adjusted profit in accordance with specific rules. If the rate falls below 15 percent in a given country, there is a basis for top-up tax. The calculation requires extensive adjustments to the accounting result and differs significantly from traditional Norwegian corporate taxation.
Collection happens through a coordinated system with three levels:
The country where the income arises can impose a domestic top-up tax.
If that doesn't happen, the ultimate parent company's country can apply the Income Inclusion Rule.
As a final backstop, other group countries, for example Norway, can apply the Undertaxed Profits Rule (UTPR).
Note that the UTPR applies to fiscal years beginning after 31 December 2024. The other methods are already in force.
The system is designed so that low-taxed income is always taxed somewhere in the group structure.
Here is perhaps the most important message: For many Norwegian businesses, the most significant practical consequence of the regime isn't the tax itself, but the reporting obligations. The regime requires a comprehensive filing, the GloBE Information Return (GIR), which can be submitted centrally at group level. This might give the impression that you as a local entity don't have any obligations of your own. But that's not the case.
As a Norwegian entity, including as a branch of a foreign company, you are in principle independently obligated to file the GIR. If the group files the return in a country that has signed the OECD's information exchange agreement (GIR-MCAA), you are not required to file it yourself. However, you still need to notify the Norwegian tax authorities about who is reporting and where. This notification obligation applies regardless. In other words, you cannot assume that the group's central processes cover your Norwegian obligations. Note that the supplementary tax return itself only needs to be filed by entities that end up being liable for the top-up tax.
2026 marks the first year of reporting under the Pillar 2 regime. If your group's financial year follows the calendar year, keep the following dates in mind:
30 June 2026: Deadline for filing the GloBE Information Return (GIR) and for notification. The standard deadline is 15 months after the end of the financial year, but for the first reporting year an extended deadline of 18 months applies.
31 July 2026: Deadline for filing the supplementary tax return (if you're required to pay top-up tax). This deadline falls one month after the main return.
Yes. Under the Undertaxed Profits Rule, group entities can be held jointly liable for top-up tax that remains unpaid. This means your Norwegian entity could face financial exposure arising from the group's overall tax position – not just its own.
In the short term, transitional rules and safe harbour arrangements can reduce the calculation burden in certain countries. But these arrangements don't change the fundamental picture: You first need to determine whether you're covered, and what obligations apply locally.
Increasingly more Norwegian businesses need to carry out an initial Pillar 2 assessment. For many, this is the first time they're encountering the rules because the connection arises through the group structure, not through their own size. Pillar 2 isn't just a group-level issue. It's also a local responsibility. Need help assessing whether your business is covered, or clarifying and fulfilling your reporting obligations? Get in touch with us for a no-obligation conversation.