Inclusive Framework on BEPS

Norway supports the outcomes of the OECD BEPS project and urges countries to implement the internationally agreed measures through the Inclusive Framework on BEPS.

Completion Status:
⚠ Unqualified*

*commitment is not specific or/and not measurable

Commitment filtering:

Specific: ❌ no

The commitment is a general statement of support for the international collaboration to end tax avoidance initiative promoted by the OECD. Although it mentions a specific initiative – the OECD Base Erosion and Profit Shifting (BEPS) project – it refers to actions to be taken by third parties (other countries). Norway signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) in June 2017, which entered into force in November 2019.[1]

[1] Organisation for Economic Co-operation and Development (OECD), Signatories and Parties to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion And Profit Shifting, For more information on tax treaties between Norway and other countries and their status in 2019, see: Norwegian Ministry of Finance, General tax conventions between Norway and other states,

Measurable: ❌ no

There is no identification of a measurable action through which Norway’s support for the outcomes of the OECD BEPS project can be assessed. Likewise, there is no mention of a measurable way in which Norway urges other countries to implement BEPS recommendations. To demonstrate Norway’s support for the BEPS initiative, the Ministry of Finance cites tax treaty agreements such as one signed with Ghana in November 2020,[1] and the additional protocol with Belgium, signed in September 2021[2]. The ministry also highlights that Norway goes further than the four BEPS minimum standards[3] when it comes to introducing the multilateral instrument for implementation of BEPS measures in tax treaties. In 2019, 28 tax agreements between Norway and other countries were modified by the MLI.[4] A modification only takes effect when both jurisdictions have made it, hence in part the need to negotiate. The Ministry of Finance has published synthesised texts to promote understanding of how the MLI applies to the treaty.[5] According to information provided by the ministry, there are currently ongoing negotiations with Brazil, Canada, China, France, Germany, Hong Kong, Iran, Liechtenstein, New Zealand, Singapore and Spain, in which Norway wants to go further than the minimum standards.  However, since the commitment itself does not refer to these actions by Norway, it cannot be considered measurable in this regard.

[1] Orbitax, Update-Tax treaty between Ghana and Norway,—Tax-Treaty-between-Gh-45100

[2] Norwegian Ministry of Finance, Convention Norway-Belgium,—belgium2/id2665993/

[3] The four BEPS minimum standards are: fighting harmful tax practices (Action 5), preventing tax treaty abuse (Action 6), improving transparency with country-by-country reporting (Action 13) and enhancing the effectiveness of dispute resolution (Action 14). Organisation for Economic Co-operation and Development (OECD), Inclusive Framework on BEPS Progress Report July 2016-June 2017,

[4] Kingdom of Norway, Status of List of Reservations and Notifications upon Deposit of the Instrument of Ratification,

[5] Norwegian Ministry of Finance, Multilateral Convention to implement BEPS Measures (MLI),

Last updated: 30 August 2022
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