The normal rate of corporate income tax in Norway is 22%.
Norwegian resident companies are subject to tax in Norway on their worldwide income.
Non-resident companies are subject to Norwegian corporate income tax on trading profits attributable to a Norwegian PE.
Domestic Norwegian legislation does not include a reference to the treaty concepts of 'permanent establishment' or 'permanent representative'. The threshold for tax liability is normally lower under Norwegian domestic law than the taxing right afforded to source states under double tax treaties (DTTs).
With respect to DTTs, the Norwegian tax authorities will, to a large extent, follow the OECD Commentaries when interpreting the relevant DTT, provided the wording is similar to the OECD Model Tax Convention.