Norway master file and local file requirements (2026)

What does Norway require at a glance?

Two obligations with different triggers, one filed and one not. Skatteetaten sets out both on one page^[1].

Who needs transfer pricing documentation in Norway?

Norway runs two tiers, and a group can owe one without the other. The disclosure attaches to the tax return and catches almost everyone: you escape it only if controlled transactions stayed under NOK 10 million in the year and related-party balances under NOK 25 million at year end. The master file and local file duty attaches to larger groups only, and the size test exempts a group with fewer than 250 employees that also has either sales under NOK 400 million or a balance sheet under NOK 350 million.

One thing the authority page does not state is the ownership percentage that makes two companies associated. That figure is not confirmed, so this page does not give one.

What goes in the Norwegian master file and local file?

The OECD content, in both cases. The master file follows the OECD group-level annex, and Skatteetaten requires it where the local file does not already carry the same information. The local file follows the OECD entity-level annex and covers the Norwegian entity's own controlled transactions.

Two things are worth knowing before you plan the work. A group revenue threshold of NOK 750 million for the master file is quoted by several secondary sources and does not appear on the authority's page, rechecked on 19 October 2026, so it is not confirmed. And the authority's own page is internally inconsistent about which regulation provisions set the local file content: one passage gives a narrower range than the legislation block beside it. We flag the discrepancy rather than pick one side of it.

Which form does Norway require with the tax return?

One controlled-transactions disclosure. It was filed on form RF-1123^[2] up to income year 2022, and from income year 2023 it sits inside the standardised tax return instead. Groups still searching for the old form are looking for something that no longer exists on its own.

This disclosure is filed. The master file and the local file are kept and produced on request. Treating them as one obligation is the most common Norway mistake.

When is Norway transfer pricing documentation due?

Three different clocks. The disclosure runs on the tax return date. The documentation runs on a request that may never come. The country-by-country report runs on the fiscal year end.

What are Norway's country-by-country reporting requirements?

The report applies to groups with consolidated revenue above NOK 6.5 billion, and a Norwegian ultimate parent files it within 12 months after the fiscal year end. Skatteetaten publishes the filing route^[3].

Notification is a separate step that names which group entity files and in which country. Its deadline and its channel are not stated on the authority page, so they are not confirmed here. Many pages merge the notification and the report into one date, which traces back to secondary guides rather than to Skatteetaten, and we do not repeat it.

What language can Norwegian transfer pricing documentation be in?

Norwegian, Swedish, Danish or English. English is accepted without prior approval, so a foreign parent needs no translation project to be compliant in Norway.

Whether the documentation has to be presented in Norwegian kroner or may use the functional currency is not stated in the sources we verified, so no rule is given here.

What are Norway's transfer pricing penalties?

Norway sets no fixed documentation penalty for transfer pricing, and the rates are not confirmed on the authority's documentation page. The exposure runs through the income adjustment instead: Skatteetaten reassesses the Norwegian entity at Norwegian corporate tax rates, so the size of the bill tracks the rate rather than a fine schedule.

Additional tax and coercive fines both exist in Norwegian tax administration generally. How they apply to a transfer pricing documentation failure, and at what rate, is not confirmed against a primary source.

How far back can Skatteetaten reassess?

Five years, and ten where aggravated additional tax is imposed or the taxpayer is reported for tax offences. Skatteetaten sets the reassessment window out^[4], though it does not say when the five years start counting.

The ten-year retention rule exists to match that worst case. A file you build this year may be read a decade from now, by someone who was not in the room when the pricing was set, which is the real argument for writing it to be understood rather than to be filed.

Can you get an advance pricing agreement in Norway?

Bilateral and multilateral only. Norway offers no unilateral advance pricing agreement, so there is no route to certainty that involves Skatteetaten alone. A bilateral or multilateral agreement is treaty-based, carries no fee, usually runs five years and generally allows rollback to up to three prior years. Skatteetaten publishes the terms^[5].

How does Norway differ from the OECD baseline?

Norway is an OECD member^[6] and an Inclusive Framework member^[7], and it follows the OECD guidelines directly, so the methods and the analysis will be familiar. Four differences matter in practice.

• Documentation is kept and produced within 45 days, never filed.
• Four languages are accepted, not one.
• The size exemption is stated in kroner, not euros, so a euro-based group threshold will not answer the question.
• The country-by-country threshold is stated as NOK 6.5 billion rather than EUR 750 million.

Norway sits in the European Economic Area but not the European Union, so European Union transfer pricing directives do not bind it directly.

How we help with Norway transfer pricing

Forty-five days is enough time to retrieve a file and nowhere near enough to write one. We build and maintain the master file, the local file and the benchmarking for each tax period, so a Skatteetaten request becomes a retrieval job, and we flag the year a Norwegian entity crosses the size test and acquires the obligation. See how our transfer pricing software works.

Book a demo to find out whether your Norwegian entity clears the documentation exemption.