Petroleum taxation

The upstream oil and gas business on the Norwegian Continental Shelf is the most important industry in Norway. The taxation of this industry is subject to special rules and strict control. 

Our specialists have extensive experience from petroleum companies, Oil Taxation Authorities and many years of industry-specific advisory activities. We offer a complete range of services related to petroleum taxation.

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How can we help you?

Tax returns

The tax return for companies subject to special tax is complicated. Several special forms must be completed, and the company must take into consideration both the ordinary onshore tax regime and the special tax regime under the Petroleum Tax Act. It is easy to make a mistake, and mistakes can prove costly.

The Oil Taxation Office’s detailed control companies subject to special tax also include requesting detailed and extensive additional information on the company’s tax positions.

We assist several companies subject to special tax in the preparation of tax returns, with tax calculations and with handling correspondence with the Oil Taxation Office.

We can assist on everything from managing the company’s entire tax function to detailed specific questions on the tax return or tax calculation.

Reassessments and disputes

The Oil Taxation Office’s control of  all companies subject to special tax so thoroughly that it effectively amounts to an annual tax audit of each company.

Many reassessment and appeals cases ensue, requiring particular attention from the companies. We have broad experience in assisting companies in reassessment cases from the Oil Taxation Office and in appeals cases to the Tax Appeals Board.

Our litigation team can handle tax cases in all tiers of the Norwegian courts.


There are frequent changes to the ownership of companies subject to special tax and licenses on the Norwegian Continental Shelf.

We provide buyer or seller Due Diligence and assist in following up on the special rules in the Petroleum Tax Act Section 10.

Transfer Pricing

Transfer Pricing is the Oil Taxation Office’s primary focus area. Most tax disputes with the Oil Taxation Office pertain to the pricing of intra-group gas sales, financial transactions, insurance, service provision or other transactions between related parties.

We assist on every aspect of Transfer Pricing, from establishing a pricing model to the handling of reassessments and disputes.

Binding Advance Rulings

Norwegian petroleum taxation involves a high tax rate and, typically, significant amounts. In some instances, it is advisable to obtain upfront clarification on tax positions through a binding advance ruling from the Oil Taxation Office.

We provide assistance on all contact with the Authorities in such instances.

International Tax

Norway has an extensive network of tax agreements with other countries.

If a tax case is not acceptably resolved in Norway, we assist in seeking the resolution of the case in accordance with the procedures available under the double tax treaties, including the Mutual Agreement Procedure (“MAP”).

Kjell Richard Manskow

Advocate | Partner, Stavanger, PwC Norway

+47 952 61 176


Per Christian Ask

Advocate | Partner, PwC Norway

+47 982 06 691


Silje Svanes Jensen

Advocate | Director, Stavanger, PwC Norway

+47 952 61 055


Øystein Andal

Advocate | Director, Oslo, PwC Norway

+ 47 952 60 291