Norway Transfer Pricing Documentation Requirements
Norway requires a Master File and Local File from groups above its size thresholds, prepared contemporaneously and produced within 45 days of a request. The obligation is linked to the duty to file the controlled-transactions form RF-1123, and documentation must be retained for at least ten years.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Groups above SME limits: ≥ 250 employees, or turnover > NOK 400m or balance > NOK 350m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 45 days. | EN / NO / SV / DA | Yes (general tax administrative sanctions) |
Local File Required | Same SME limits as the Master File | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 45 days. | EN / NO / SV / DA | Yes (general tax administrative sanctions) |
CbC report Required | Group revenue ≥ NOK 6,500m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Norway deadline
Enter your entity’s fiscal year-end to return your exact Norway preparation or filing date. Available without registration.
Scope of the documentation obligation
An entity that is obliged to file the controlled-transactions form RF-1123 is, as a starting point, also obliged to hold full transfer pricing documentation in the form of a Master File and a Local File. Small and medium-sized enterprises are exempt, defined as those belonging to a group with fewer than 250 employees and either turnover not exceeding NOK 400 million or a balance sheet total not exceeding NOK 350 million. The test is applied on a globally aggregated basis across the entire group. Documentation is produced on request, and must be provided within 45 days.
Distinctive features of the Norwegian regime
Two practical features mark the Norwegian regime. The first is the long retention period: transfer pricing documentation must be kept for at least ten years, which is considerably longer than the general assessment window and shapes how groups archive their analyses. The second is the Norwegian Tax Administration’s comparables practice. It tends to prefer local or Nordic comparables, and while pan-European benchmarks are accepted they are frequently challenged. There have been instances of the authority relying on secret comparables, although this is not regarded as common practice. No specific safe harbour is published.
Benchmarking and comparables
Local or Nordic comparables are preferred, and where local comparables are unavailable it is advisable to present foreign comparables, recognising that pan-European sets may be challenged. Multi-year testing is the common approach. A fresh search is not required every year, although it can be requested; current practice is a three-year cycle with financial updates in the two intervening years. The general limitation period for tax assessments is five years, while the documentation retention obligation runs to at least ten years.
Frequently asked questions
How long must transfer pricing documentation be retained in Norway?
At least ten years. This is longer than the general five-year assessment period, so documentation should be archived to remain retrievable well beyond the point at which a year would ordinarily close.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.