Is the tax amnesty in Norway ending? - proposed changes

In recent years, the Norwegian tax system has been highly flexible, based on trust in taxpayers. The Norwegian tax office allowed corrections going back as far as 10 years - without the risk of additional penalties (provided the tax office had not already started an audit). This was clearly very convenient for taxpayers.

Now, however, the government plans to introduce significant restrictions in this area. The proposed changes, sent out for consultation on 9 October 2024, include, among other things, the abolition of the current relief in the form of the so-called "skatteamnesti".

What does this mean in practice? Find out, especially if in the past you did not include something important in your tax returns, such as foreign property, income from other countries, or other items that the tax office may learn about from external sources (that is, almost everything).

Current rules - what is still possible today?

1. Amnesty for up to 10 years back - current rules allow tax returns to be corrected going back as far as 10 years. If we disclose outstanding information ourselves, we avoid additional penalties - it is enough to pay the tax due and any interest.
2. Self-correction - we can correct both errors that work in our favour and those that result in additional tax, provided we do it ourselves - that is, before the tax office starts an audit.
3. Tax office audit - if the tax office discovers irregularities, in addition to tax and interest, additional penalties may be imposed (20%, 40% or even 60% additional tax). In the case of deliberate fraud, the tax office may examine matters going back up to 10 years.

Planned changes - the end of amnesty?

The government is seeking to abolish the current amnesty. The main consequences are, above all:

1. Shortening the correction period - instead of 10 years, we will only be able to make corrections going back 3 years. Regardless of whether the correction is beneficial to us or not.
2. Limited ability to avoid penalties - after the changes, avoiding an additional penalty by voluntarily reporting outstanding matters will be much more difficult. Although in some situations it will still be possible to avoid penalties, in more serious cases this may prove impossible.
3. Higher risk in the case of long-term breaches - in the event of serious negligence, the tax office will still be able to go back 10 years and impose additional tax. Voluntarily reporting errors after the new rules enter into force will no longer guarantee full protection from penalties.

What does this mean for you?

• If in recent years (even up to 10 years back) you have omitted income, foreign property, or incorrectly determined your tax residence, it is worth considering a correction while the current, more favourable rules still apply.
• After the changes are introduced, the period for penalty-free correction will only be 3 years back.
• Even voluntarily correcting long-standing or deliberate errors will no longer guarantee that you avoid a penalty.

When will we know the final rules?

A decision should be made by 9 January 2025, and the final date on which the new regulations will enter into force will be announced later. It is worth following the latest updates and - if you are considering a correction - consulting a specialist (for example, us 😊) before the rules change.

Summary

The upcoming changes will probably mean the end of freely correcting old tax returns without worrying about penalties from the tax office. This is the last chance to sort out tax matters under the old rules.

If you have any doubts about your situation, would like to submit a correction, or have any questions - please contact us: +47 21 38 38 21.
We answer Mon-Fri from 9:00 - 21:00 and will be happy to help!