On 28 October 2026, the Norwegian Tax Administration published new guidance on customs declaration procedures for transfer pricing adjustments. The updated regime allows importers to declare transfer pricing adjustments directly in the customs declaration, eliminating the need for separate voluntary disclosure processes that previously created significant administrative burden. The guidance outlines the conditions under which the simplified declaration can be used, including requirements for documentation, timing, and the types of adjustments covered. This development aligns with OECD transfer pricing guidelines and EU customs valuation rules, providing greater certainty for multinational enterprises operating in Norway. The new procedure is effective immediately and applies to all imports where a transfer pricing adjustment increases the transaction value declared to customs.
Key Takeaways
- Simplified Declaration Process: Importers can now include transfer pricing adjustments in the standard customs declaration (SAD) using specific codes, removing the requirement for separate correction declarations and reducing processing time.
- Documentation and Timing Requirements: The regime requires that transfer pricing adjustments be supported by contemporaneous documentation and that the declaration be made within the statutory limitation period, typically three years from the original import date.
- Scope and Limitations: The simplified procedure applies only to adjustments that increase the customs value; reductions in value still require a separate repayment claim. Additionally, the regime does not apply to adjustments related to customs duties that have already been subject to a final assessment.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement