Executive Summary
This week’s Norwegian tax intelligence focuses on significant VAT procedural changes, including a proposed three-year limitation period for VAT compensation claims and the mandatory transition to standardized VAT access packages in Altinn from January 2027. Operational updates cover new customs declaration procedures for transfer pricing adjustments, digitalization of A1 social security certificates, risks triggering exit from the Norwegian shipping tax regime, and mechanics of half tax deduction in payroll.
Important Updates
Proposed Three-Year Limitation Period for VAT Compensation Claims
On 14 October 2026, the Norwegian Ministry of Finance released a consultation paper proposing a statutory three-year limitation period for VAT compensation claims under Section 11-1 of the VAT Act (Merverdiavgiftloven). The proposal seeks to replace the current open-ended claim period under which claims dating back 10-15 years are possible with a fixed deadline calculated from the end of the calendar year in which the VAT became chargeable. For example, VAT overpaid in 2025 must be claimed by 31 December 2028. The proposal also introduces an explicit taxpayer right to self-correct within the same three-year window, moving self-correction from administrative discretion to a statutory entitlement.
The consultation runs until 15 January 2027, with expected legislative adoption in Spring 2027 and entry into force on 1 January 2028. Transitional rules provide that claims relating to periods before 1 January 2025 remain subject to the current reasonable time standard until 31 December 2027, after which the three-year rule applies universally. The change affects all VAT-registered entities in Norway, particularly real estate (partial exemption), financial services, public sector bodies, cross-border B2B service providers, importers discovering overpaid import VAT, and non-resident businesses registered via a tax representative. Non-compliance results in forfeiture of the right to compensation, with no additional fines envisaged.
Sources: PwC Norway
Mandatory VAT Access Package in Altinn from 1 January 2027
The Norwegian Tax Administration has mandated that, from 1 January 2027, all individuals handling VAT matters on behalf of a business must hold the correct access package (tilgangspakke) in Altinn, the national digital dialogue platform. Legacy Altinn roles and role delegations used for VAT reporting will be permanently removed. For most Norwegian businesses, the VAT return for the sixth reporting period of 2026, due on 10 February 2027, will be the first filing submitted under the new access package regime without the old role structure.
The modernization moves Altinn’s authorization framework from granular role-based access to standardized access packages bundling permissions for specific business processes. Companies must audit current access rights for internal employees and external advisors, including accountants and tax lawyers, well before the year-end transition. Third-party software providers integrating with Altinn’s API must ensure their solutions support the new authorization model. Failure to assign the correct VAT access package will prevent return filing, triggering late-filing penalties and interest charges under the Tax Assessment Act. PwC recommends completing a gap analysis by November 2026 to allow time for remediation.
Sources: PwC Norway
Secondary Regulatory & Regional Updates
- New Customs Procedure for Transfer Pricing Adjustments: Effective 28 October 2026, the Norwegian Customs Authority introduced a consolidated customs declaration scheme allowing importers to file a single annual declaration for transfer pricing adjustments increasing customs value, rather than individual amended declarations per shipment. The scheme requires a valid AEO certificate, contemporaneous transfer pricing documentation, and advance notification. Importers must register intent by 30 November 2026 for the 2026 income year, with the consolidated declaration due by 31 October 2027. Downward adjustments remain excluded. Non-compliance may incur fines up to NOK 500,000 and AEO revocation. PwC Norway
- Digitalization of A1 Certificate and Payroll Chain: From 1 January 2027, NAV will reject paper-based A1 applications for postings exceeding one month, requiring end-to-end digital processing via NAV’s APIs and integration with payroll systems consuming structured XML/JSON responses. Employers must submit A1 applications before postings commence and map correct social security contribution rates in the a-melding. Incorrect A1 management exposes employers to unpaid contributions (14.1%-25.6%), employee arrears (8.2%), and potential sanctions for illegal employment. A gap analysis is recommended by Q4 2026. PwC Norway
- Pitfalls Triggering Exit from Norwegian Shipping Tax Regime: Sale of the last vessel, re-flagging to non-qualifying registries outside the EEA or approved registries, and intra-group reorganisations altering vessel ownership or tax residency can automatically trigger exit from the tonnage tax regime under Chapter 15 of the Taxation Act. Exit is retroactive to the beginning of the income year, converting prior tonnage tax calculations to ordinary corporate tax with interest. A 20% negligence penalty applies to underpaid tax. Companies should obtain advance tax rulings for complex restructurings and review fleet ownership and flag status before executing transactions. Regnskap Norge
- Mechanics of Half Tax Deduction in Norwegian Payroll: The halvt skattetrekk mechanism under the Tax Payment Act section 10-10 requires employers to withhold tax on only 50% of specified allowances (e.g., travel allowances, offshore supplements, non-resident director fees) at the table rate, with the remaining half taxable at final annual assessment. Employers must correctly code allowances in the a-melding by the 5th of the following month. Coding errors trigger employer liability for under-deducted tax plus a 20% penalty. Employees with recurring allowances should request revised tax deduction cards to spread the liability. Regnskap Norge
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.