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NorwayRevisorforeningen

Auditors should attest CbCR publication only where duty applies

Revisorforeningen backs directive-based rules but says the audit statement on the tax report should cover only undertakings with the duty, exempting small ones at least.

By Taxxa AI OyPublished 2 October 2026

Tax Audit

Norway is implementing the EU directive on public country-by-country tax reportingRevisorforeningen, directive (EU) 2021/2101Revisorforeningen of 24 November 2021, which amends the Accounting Directive (2013/34/EU)Revisorforeningen. Finansdepartementet proposes a reporting duty in line with the directive's minimum requirementsRevisorforeningen, and Revisorforeningen supports that directive-based implementation. In a consultation response published 2 October 2026Revisorforeningen, the association comments mainly on the proposed statements in the auditor's report.

Under the proposal, the auditor must state in the revisjonsberetning whether the audited undertaking had a duty in the preceding financial year to publish a public country-by-country tax reportRevisorforeningen, and if so, whether the report was publishedRevisorforeningen. The requirement derives from new Article 48f of the Accounting DirectiveRevisorforeningen. As drafted, it would apply to every auditor's reportRevisorforeningen. Revisorforeningen argues the audit statement should be limited to undertakings that actually carry the reporting dutyRevisorforeningen, and at a minimum that small undertakings should be exemptRevisorforeningen, since the proposal goes further than the directive requires.

The reporting duty itself falls on parent companies and standalone undertakings active in several countriesRevisorforeningen: they must publish a country-by-country report with information on the group's business and tax payments in the countries where they operate. The duty also covers medium-sized and large subsidiaries and branches of groups whose parent sits outside the EEA, unless such a report is published elsewhere in the EEARevisorforeningen. It applies where the group has had consolidated revenue above NOK 7.5 billion per yearRevisorforeningen in each of the last two financial yearsRevisorforeningen.

The report must describe the business, the number of employees, revenues, profit before tax and accrued and paid income tax, broken down by country for EEA states and the EU lists of non-cooperative tax jurisdictions, with the rest of the world reported in aggregate. It must be published no later than twelve months after the balance-sheet dateRevisorforeningen through the RegnskapsregisteretRevisorforeningen and kept available on the undertaking's website for at least five yearsRevisorforeningen. On stated conditions, individual items may be deferred for up to five years, with such omissions clearly marked and reasoned.

This public reporting regime is distinct from the existing confidential country-by-country reporting to the tax authorities, where large multinational groups with consolidated income above NOK 6.5 billion per year report to SkatteetatenSkatteetaten within twelve months of the financial year-endSkatteetaten. The new duty makes the figures reader-facing, which is why the auditor's statement about publication matters to users of the accounts.

Legal basis: directive (EU) 2021/2101 amending directive 2013/34/EU, including new Article 48f; the Finansdepartementet consultation proposal implementing it in NorwayRevisorforeningen.

Auditors of undertakings that may fall under the proposed duty should track the consultation and prepare auditor-report statements on the country-by-country report in line with new Article 48f.

Sources