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CMS Expert Guide to Mastering OECD's Pillar Two in Norway

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force?
  5.  When will the Undertaxed Payments Rule (UTPR) come into force? 
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
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1.Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

In May 30, 2023: the legislative proposal regarding Pillar Two (Wetsvoorstel minimumbelasting 2024) was submitted to the House of Representatives of the States General. 

3. Have your tax authorities published guidelines commenting on Pillar Two/GloBE rules?

There are explanations in the White Paper presenting the Supplementary Tax Act. However, these are based directly on OECD comments and guidelines, which are generally applicable.

4. When will the Income Inclusion Rule (IIR) come into force?

2024.

5. When will the Undertaxed Payments Rule (UTPR) come into force? 

Likely in 2025 (to be enacted  later)

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

Yes, from 1 January 2024