International taxation

With offices and colleges in more than 150 countries, PwC is the worlds largest network of lawyers, accountants and consultants, who are all ready to help your organisation with questions dealing with local and international tax and law. 

Matters which potentially may result in need for assistance are for instance:

  • business activities are or are to be established in another country
  • cross-border trading, investments, transactions or restructuring
  • challenges related to double taxation of income, capital transactions to owners
  • tax optimisation of ownership structure, localisation of IP and other assets

Continuous development in international tax and regulatory framework conditions

Multi-national companies are increasingly affected by a continuous development in national and international tax-, juridical- and regulatory framework conditions. To understand the effect of this development business management and transactions between countries is critical for the success of a company.

This applies not only to reporting correctly and in a timely manner in the countries in question, but also predicting the consequences of future actions and organisation, so that one in advance can tax-optimise the activities and structure of the company and group.


How can we help you?

Assistance in cross-border activities

When doing cross-border activities it is important to be aware of the risk of tax implications, double taxation and obligation to report.

PwC can, together with the international PwC-network, among others help with services related to:

  • Assessment of tax duty / permanent place of business and taxable home country
  • Establishing a branch, determining input values for assets, etc.
  • Ongoing taxation of branches
  • Credit of Norwegian tax for tax paid abroad
  • Questions regarding allocation of income and cost
  • Choice of business structure when doing cross-border activities (commission agreement, agents, buy-sell structure) and establishing framework
  • Taxation on termination or relocation of businesses (exit)
  • Assistance in the event of disagreement with Norwegian and foreign tax authorities - handling complaints and legal assistance

Tax reporting in Norway and abroad

The consequences of not complying with reporting obligations at home and abroad can be costly, both as a result of additional tax, fees, double taxation and criminal sanctions. The PwC network can assist with:

  • Assistance tax returns and other tax reporting obligations for companies and branches at home and abroad
  • Registration of branches
  • Reporting of third-party information
  • Reporting of investments in foreign mutual funds
  • DAC 6 reporting
  • FATCA reporting

Cross-border investments

Taxable reporting duties, hybrid classification, hybrid capitalisation, current taxation and avoiding double taxation are questions that often are decisive for the profitability of the investment. Feel free to contact us for more information about:

  • Tax classification of foreign investments and shareholders, application of exemption method and tax agreement
  • Structuring and capitalisation of investments
  • Withholding tax - reimbursement or pre-approval for exemption from withholding tax liability in the withholding state
  • Credit in Norwegian tax for withholding tax paid abroad 
  • Holding companies 
  • Interest rate limitation NOK and abroad
  • Classification questions
  • NOKUS taxation and reporting


Cross-border transactions

  • Cross-border reorganisations and investments as mergers, fissions and profit on shares
  • Acquisition of investment, company, business in another state
  • Realisation of investment, company, business in another state

EU / EEA law

EEA law is very central in international tax law. PwC's assistance has led to changes in Norwegian law so that EEA citizens have the same rights as Norwegian tax payers. We can assist with:

  • Advice related to EEA law and tax
  • Challenge Norwegian law and practice by e.g. discrimination against EEA citizens, state aid
  • Assistance in complaints to ESA, legal aid in the EFTA Court, etc.

Tax contract law, MLI and BEPS

Assessment of tax treaties is essential to avoid double taxation of income, obtain credit for taxes paid abroad, etc.

Changes in tax treaties with the OECD's Multilateral Instrument (MLI) entail changes in a number of tax treaties. In addition, the OECD's BEPS project (Base Erosion Profit Shifting) which aims to prevent the exploitation of the tax agreement network has been a hot topic for several years. PwC is happy to assist in assessing the consequences this will have for the individual customers.

Tax disputes, MAP and APA

In many cases, the tax authorities challenge the taxpayer's claim of tax agreement - with a possible consequence is that income is double taxed. PwC can assist with both complaint handling, requirements for MAP (Mutual Agreement Proceedings - cooperation between the tax authorities in the relevant countries) and APA (Advance Pricing Agreements - an advance agreement between the state on transfer pricing for the companies).

Special tax regimes - offshore, energy taxation, bank and finance

Norway has many tax regimes where there also is special regulations. We have experts who can help assess how international question are made applicable also for special tax regimes.

Contact us

Ståle Wangen

Advocate | Partner, Oslo, PwC Norway

+ 47 952 60 816


Hilde Thorstad

Advocate | Partner, Oslo, PwC Norway

+ 47 952 60 548


Lars Hallvard Walby

Advocate | Partner, Oslo, PwC Norway

+ 47 481 61 795