How we can help
VIEW Tax, through strategic partnership with a Norwegian transfer pricing boutique networked in over 40 countries, can provide transfer pricing advisory and compliance services to reduce your company’s risk and optimize your tax position in Norway. Feel free to contact us if you’d like to discuss Norwegian transfer pricing considerations further.

Transfer pricing confirmed as tax audit area of focus by Norwegian Minister of Finance
On 3 February 2020 the Minister of Finance reaffirmed to the Norwegian Parliament that transfer pricing remains a primary focus area of tax audit and scrutiny for historical, current and future tax years.

Are you liable to produce documentation
In general, Norwegian taxpayers with NOK 10 million or more in intercompany transactions in the year are required to submit transfer pricing documentation.

A small group exemption to the documentation requirements is provided for taxpayers that are members of a group of companies with fewer than 250 employees worldwide AND with aggregate group revenue in the year under NOK 400 million (or an outstanding group balance of under NOK 350 million).


Feel free to contact us if you’d like to discuss Norwegian transfer pricing considerations further.

Transfer pricing documentation 
The starting point for the Norwegian audits is typically a taxpayer’s transfer pricing documentation. This documentation is a compliance requirement for many companies, branches and permanent establishments operating in Norway.

Failure to provide transfer pricing documentation allows for the Tax Authority to make a “discretionary adjustment”, which means that the Tax Authority can determine the amount of tax they believe the taxpayer has underpaid.

Thus, the burden of proof is transferred from the Tax Authority to the taxpayer making it substantially more difficult for the taxpayer to successfully argue its position.