Norway

Transfer Pricing in Norway

Norwegian transfer pricing for income year 2026: companies and permanent establishments that deal with related parties. Covers the arm's length rule in skatteloven § 13-1 (including the reversed burden of proof for counterparties outside the EEA), the controlled-transaction statement filed with the tax return and the written documentation duty in skatteforvaltningsloven § 8-11 (the 50% related-party test, the NOK 10 million transactions / NOK 25 million balances exemption, the 250 employees / NOK 400 million sales / NOK 350 million balance sheet small-group exemption, 45 days to produce documentation, ten-year retention), the documentation contents in the regulation, country-by- country reporting at NOK 6.5 billion, additional tax of 20% plus 20% or 40%, coercive fines and the five-year change window.