In recent years, the Norwegian tax system has been very flexible, based on trust in taxpayers. The Norwegian tax office allowed corrections going back 10 years – without the risk of additional penalties (if the office had not yet started the audit). This was definitely convenient for taxpayers.
Now, however, the government plans to introduce significant restrictions in this matter. The proposed changes, sent for consultation on 9 October 2024, include, among other things, the abolition of the currently applicable relief in the form of the so-called "skatteamnesti".
What does this mean in practice? Find out, in particular, if you have not included something important in your tax returns in the past, such as foreign real estate, income from other NOKs or other items that the tax office can find out about from external sources (which means almost everything).
Current rules – what else is possible today?
Amnesty up to 10 years back – current regulations allow for correction of returns up to 10 years back. If we disclose the overdue information ourselves, we will avoid additional penalties - just pay the tax and any interest.- Do-it-yourself proofreading – We can correct errors, both those that work to our advantage and those that result in additional tax payments, provided that we do it ourselves – i.e. before the office starts the inspection.
- Official control – If the office detects irregularities, additional penalties (20%, 40% or even 60% of the additional tax) may be imposed in addition to the tax and interest. In the case of intentional fraud, the office may investigate cases up to 10 years back.
Planned changes – the end of abolition?
The government is seeking to abolish the current amnesty. The main consequences are primarily:
- Shortening the correction period – frominstead of 10 years, we will only be able to make corrections up to 3 years back. Regardless of whether the correction will be beneficial for us or not.
- Limited opportunities to avoid penalties – After the changes, avoiding an additional penalty by reporting arrears yourself will be much more difficult. Although in some situations it will still be possible to avoid penalties, in the case of more serious violations it may be impossible.
- Increased risk with long-term violations – in the case of gross negligence, the office will still be able to go back up to 10 years and impose additional taxes. Reporting errors yourself after the new regulations come into force will no longer guarantee full protection against penalties.
What does this mean for you?
If in recent years (even up to 10 years back) you have omitted income, foreign real estate or incorrectly determined your tax residence, it is worth considering a correction under the current, more favorable rules.- After the changes are introduced, there will only be a 3-year retroactive period for correction without penalties.
- Even voluntarily correcting long-standing or intentional mistakes will no longer guarantee avoidance of punishment.
When will we know the final regulations?
The decision should be made by January 9, 2025, and the final date of entry into force of the new regulations will be announced later. It is worth monitoring current information and - if you are considering a correction - consult a specialist (e.g. us 😊) before the regulations change.
Summary
The upcoming changes probably mean the end of freely correcting old settlements without fear of penalties from the office. This is the last call to sort out tax issues under the old rules.
If you have any doubts about your situation, would like to make a correction or ask a question, please contact us: +47 21 38 38 21.
We collect Mon.-Fri. from 9:00 a.m. to 21:00 p.m. and we will be happy to help!
