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Norway Consulting on Implementation of Pillar 2 UTPR from 2025

21 June 2024

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Proposed Changes

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Norway

The Norwegian Ministry of Finance has launched a public consultation on proposed amendments to the Supplementary Tax Act. As previously reported, the Act introduced an income inclusion rule (IIR) and a domestic minimum top-up tax in line with the Pillar 2 GloBE rules that apply for financial years beginning after 31 December 2023 (the 2024 income year). The proposed amendments include the introduction of an undertaxed payment/profit rule (UTPR) that, subject to approval, will apply from the 2025 income year.