Tax services
We help you navigate an increasingly complex tax and legal landscape, both in Norway and internationally.
With 200 specialists in tax, legal and business law services, we are one of Norway’s largest and most experienced professional environments. Our lawyers and advisors combine deep technical expertise with industry insight and access to a global network spanning more than 150 countries.
The result is advice that is precise, practical and tailored to your business, whether you are a Norwegian company with international ambitions, a multinational group operating in Norway, or a public sector entity facing complex challenges.
We see tax and legal matters as an integrated part of business strategy, not as isolated functions. Through close collaboration with PwC’s other service areas in audit, consulting, deals and legal services, we deliver holistic solutions that support your entire value chain.
We are one of Norway’s largest legal environments within tax, indirect tax and business law, and the only one fully integrated with a global advisory network. No other law firm in Norway can offer the same combination of legal depth, multidisciplinary breadth and global reach.
Our tax services
Tax law affects every major business decision, from day‑to‑day operations to the largest and most complex transactions. Our role is not only to provide answers, but to help your organisation become better equipped to manage tax matters independently. We build capability within our clients, establish robust processes and deliver tools that make the tax function more efficient and strategic. Whether the task is to ensure accurate reporting, optimise tax positions or defend your positions in discussions with the authorities, our objective is always that you are stronger after working with us.
Our tax team consists of lawyers, economists and advisors with experience from the private sector, public authorities and academia. We understand that tax does not exist in isolation, but is closely linked to accounting, finance, law and business strategy. That is why we work in multidisciplinary teams and closely with your organisation, ensuring that our advice makes an impact where it matters most. Through PwC’s global network, we can mobilise specialist expertise in more than 150 countries at short notice, coordinated from Norway and tailored to your needs.
The strongest tax functions are those that do not merely respond to change, but stay ahead of it. Our role is to help our clients get there.
How our tax experts can help you
National corporate taxation
Norwegian corporate taxation has become more complex and less transparent, while the consequences of errors have never been greater. The rules change frequently and simplification is rarely the outcome. For businesses making decisions on investments, acquisitions, dividend distributions, demergers and mergers, it is critical to understand the interaction between tax, accounting and reporting.
We consider both opportunities and risks, with the objective that you pay the right amount of corporate tax, aligned with your commercial objectives and applicable regulations. We analyse the financial impact of alternative tax solutions, ensure timely and accurate tax reporting, and support you in tax audits and in dialogue with the Norwegian Tax Administration. We also assist with tax disputes and appeals where needed.
With in depth knowledge of Norwegian corporate taxation and a strong global network, we help you identify the best solution for your specific situation, whether it relates to a single transaction or your ongoing tax position.
Tax rules are constantly changing, but the objective remains the same: to ensure that your tax position supports your commercial objectives, rather than standing in their way.
International tax
When business activities cross borders, questions arise around tax liability, permanent establishment, withholding tax, CFC rules and Pillar Two. The interaction between Norwegian tax law, tax treaties, EU and EEA law, and OECD guidelines is complex, and the consequences of incorrect assessments can be significant.
We support clients across the full range of international tax matters, from foreign establishment to exit, and from day to day operations to dispute management. This includes everything from the structuring and capitalisation of investments to the interpretation of tax treaties and the implications of the OECD’s Multilateral Instrument (MLI) and the BEPS project. EEA law is a key element of our advice, and our work has contributed to changes in Norwegian legislation to ensure equal rights for EEA citizens and companies.
Our global network ensures precise and coordinated advice, regardless of the jurisdictions in which you operate.
International tax is not only about avoiding double taxation, but about building structures that create value at every stage.
Deals Tax – Transaction tax services
In every transaction, whether it involves an acquisition, restructuring, exit or fund structuring, tax and indirect tax considerations are critical to value creation. Insufficient tax planning can result in unnecessary tax leakage and lost synergies, while effective structuring can make the difference between a good outcome and an exceptional one.
Our specialists have extensive experience from both domestic and cross‑border transaction processes, including structuring, tax due diligence for both corporate and private equity clients, negotiations related to share purchase agreements, and implementation. We are fully integrated across PwC’s Deals and Tax practices, allowing us to view the entire transaction process in context and deliver joined‑up advice.
The Norwegian Deals team works closely with PwC’s global Deals network of more than 1,700 professionals across 60 countries, ensuring coordinated advice regardless of where the transaction takes place.
Our value‑driven approach helps you realise tax synergies, eliminate unnecessary tax leakage and establish a framework that ensures compliance with both national and international tax regulations.
Tax reporting and compliance
The consequences of insufficient tax reporting can be significant, including additional tax, penalties, double taxation and criminal sanctions. At the same time, regulatory requirements continue to increase year by year. Pillar Two, DAC6, FATCA and country‑by‑country reporting place growing demands on a company’s systems, processes and internal capabilities.
We take responsibility for the entire reporting chain, from tax returns and branch registrations to third‑party reporting and compliance in Norway and internationally. Our specialists combine experience from both the Norwegian and global network with technology solutions and data‑driven insights, offering a proactive and integrated approach to your reporting challenges.
We also provide operational tax support, including assistance to in‑house tax functions, digital solutions and strategic assessments.
Reporting is not just about meeting deadlines. It provides a window into your organisation’s tax positions, risks and opportunities.
Transfer pricing
Transfer pricing is one of the most critical and closely scrutinised tax areas for groups with cross‑border transactions. Tax authorities in Norway and internationally place significant focus on this area, and requirements related to reporting, documentation and transparency continue to evolve. Businesses without a clear strategy and effective internal processes face substantial risk.
We have one of the largest transfer pricing practices in the Nordics, with deep expertise across industries and jurisdictions. We support clients with everything from transfer pricing documentation and benchmarking studies to APA negotiations, MAP procedures and dispute management in connection with tax audits. Within the petroleum sector, transfer pricing is the Norwegian Petroleum Tax Office’s primary focus area, and we have extensive experience with the pricing of intra‑group gas sales, financial transactions and services between related parties.
We are part of PwC’s global transfer pricing network, comprising more than 4,000 specialists across over 80 countries.
A strong transfer pricing strategy is not just about compliance. It gives you control over risk and visibility into opportunities.
Our indirect tax services
The indirect tax landscape is characterised by high complexity, frequent regulatory changes and increasingly active tax authorities. For most businesses, VAT represents the largest indirect tax exposure and is often the area with the greatest risk of error. Our approach goes beyond resolving individual issues. We help you build systems, routines and internal capabilities that ensure indirect tax processes work effectively in day‑to‑day operations, not only when an advisor is present. We strengthen your finance function, making it more reliable, accurate and better equipped to identify both risks and opportunities.
With Norway’s largest indirect tax practice, covering domestic VAT, international trade, customs, excise duties, CBAM and compliance, we have the breadth and depth required to handle all types of indirect tax matters. Many of our specialists have backgrounds from the Norwegian Tax Administration and Customs, giving them first‑hand insight into how the authorities operate. We use this insight to provide practical, operational advice that stands up both in daily operations and during audits.
Indirect tax affects the entire business, from procurement and logistics to invoicing and reporting. When we succeed, our clients see fewer errors, lower risk and stronger control.
How our indirect tax experts can help you
Domestic VAT
Value added tax is a risk area that requires continuous attention. Errors in VAT handling can result in significant reassessments, penalties and interest charges, while at the same time there are often savings opportunities that remain unutilised.
We have extensive experience supporting clients with everything from tax audits and VAT reviews to dispute resolution, dialogue with the tax authorities and ongoing advisory services. Our experts have experience across a wide range of industries, including energy, oil and gas, aquaculture, telecoms, financial services, retail, defence and shipping, and we understand what it takes to succeed in your sector. We offer everything from high‑level reviews based on sampling to detailed analyses resulting in a written report with concrete improvement measures.
We also support clients across the full scope of VAT related to real estate, including development, leasing and adjustment rules, as well as appeals and assistance during tax audits.
Effective VAT management is not just about avoiding errors. It is about being able to take advantage of the opportunities the regulations actually provide.
International VAT
Companies engaged in international trade face an increasingly complex commercial environment, where international VAT, customs duties, excise duties, rules of origin and sustainability related charges must be managed carefully and addressed in an integrated manner. Our international trade team has extensive experience advising on how invoicing, flows of goods and services, and business organisation impact registration, reporting and documentation obligations in Norway and abroad. Effective indirect tax management can improve cash flow, reduce errors, enable more efficient reporting and lower the risk of unforeseen costs related to cross‑border transactions.
We have Norway’s largest and most experienced team in this area, with expertise drawn from roles as lawyers, advisors and former professionals within customs and tax authorities. Through PwC’s global network, we collaborate with more than 1,900 indirect tax specialists across 150 countries, ensuring that Norwegian and international businesses receive coordinated support where their activities actually take place. We assist, among other things, with foreign establishments and VAT registrations abroad for both B2B and B2C activities, VAT refund claims, fiscal representation, and reviews of goods, services and invoicing flows, as well as ERP and reporting matters. Our services also include assessments of intra‑group transactions, customs valuation, origin and preferential duty treatment, excise duties and other sustainability‑related requirements.
Our services are particularly relevant for businesses with cross‑border sales, procurement, production, warehousing, installations, e‑commerce activities or group structures spanning multiple jurisdictions. We work across industries including industrials and trade, aquaculture and seafood, energy and renewables, shipping, offshore, oil and gas, and technology and media. We also offer tailored workshops, development of internal guidelines and practical support in dialogue with Norwegian and foreign authorities, helping make international trade easier to manage in everyday operations.
Cross‑border trade is not only about customs at the border. It is about making VAT, documentation, reporting, and the flow of goods and services work together. Done right, indirect tax becomes part of the business model, not a barrier to growth.
Compliance and SAF‑T
Requirements for indirect tax compliance continue to increase, with more detailed reporting, digital audit mechanisms and stricter sanctions for non‑compliance. SAF‑T (Standard Audit File for Tax) has become a key audit tool for tax authorities and places high demands on a company’s accounting and reporting systems.
We support ongoing VAT reporting in Norway and act as VAT representative for foreign businesses.
We also offer workshops and ongoing advisory services covering what SAF‑T entails, the selection of implementation solutions and how the requirements should be tailored to your organisation. We have developed our own conversion solution tailored to SAF‑T Financial in Norway and deliver a wide range of analysis and validation services, from technical validation with more than 30 controls to accounting analysis presented in a Power BI dashboard. We use SAF‑T as a lever to improve the quality of VAT reporting and identify deviations.
Within broader indirect tax compliance, we support clients with both high‑level and detailed reviews, verification of reporting requirements, establishment of internal control procedures and training of the finance function.
SAF‑T is more than reporting. It delivers insight into the quality of your indirect tax management.
VAT in public and non‑profit sectors
Municipalities and county authorities are entitled to VAT compensation. Private entities delivering statutory municipal services may also fall within the scope of the VAT compensation scheme. The regime is complex, and significant amounts may be lost if it is not handled correctly. The compensation rules are particularly challenging in connection with construction projects, leasing of real estate, and the distinction between compensable and non‑compensable activities.
Non‑profit organisations may apply for VAT compensation under a separate scheme administered by Lotteri- og stiftelsestilsynet. The scheme is framework‑based, and proper documentation is critical to ensure that the organisation receives the compensation to which it is entitled. Many organisations miss out on substantial amounts due to incomplete applications, insufficient documentation, or an unclear understanding of how the rules should be applied.
There is also a specific refund scheme for VAT applicable to health trusts. The purpose of the scheme is to ensure that VAT considerations do not influence decisions between in‑house production and procurement from private suppliers. In practice, the scheme is technically complex, with challenging distinctions between compensable purchases and costs that fall outside the scope of the scheme.
We support private entities, non‑profit organisations, health trusts, municipalities and county authorities in ensuring correct classification and documentation in order to secure VAT compensation under the applicable regimes. We have also assisted in a number of disputes with the tax authorities before the courts.
VAT compensation schemes represent significant value for both the private and public sectors, but they require precision and a long‑term approach. We help you deliver both.
We support the evaluation of existing regulations and provide input to new frameworks, using these insights to help our clients stay ahead of developments.
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