Ries
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I would recommend that Milei look at the way Norway taxes the companies it lets do raw materials extraction-
A Norwegian resident company is, as a starting point, subject to corporate income tax (CIT) on its worldwide income. Non-resident companies are, as a starting point, liable for CIT in Norway when engaged in a business that is either conducted in or managed from Norway.
CIT is, in general, assessed at a rate of 22%. Certain companies within the financial sector are assessed at a CIT rate of 25%.
As a general rule, income is taxable when the right to receive it arises and costs are deductible when the liability to cover the costs arises. The actual payment is generally not relevant.
Taxation is based on net income at a marginal tax rate of 78%, which comprises the ordinary 22% CIT rate and a 56% special tax. All income is subject to 22% CIT, while only income from offshore production and pipeline transportation of petroleum on the NCS (offshore tax regime) is subject to the additional 56% special tax.
Following the 2022 shift to a ‘sequential’ tax system, tax on upstream petroleum tax activities is calculated in two steps. Firstly, the tax in the ordinary 22% tax base is calculated. The resulting tax amount is then deducted from the special tax base, on which a ‘technical special tax rate’ of 71.8% is applied in order for the overall effective tax rate to remain 78%:
Norway
Corporate - Taxes on corporate income
Last reviewed - 23 January 2024A Norwegian resident company is, as a starting point, subject to corporate income tax (CIT) on its worldwide income. Non-resident companies are, as a starting point, liable for CIT in Norway when engaged in a business that is either conducted in or managed from Norway.
CIT is, in general, assessed at a rate of 22%. Certain companies within the financial sector are assessed at a CIT rate of 25%.
As a general rule, income is taxable when the right to receive it arises and costs are deductible when the liability to cover the costs arises. The actual payment is generally not relevant.
Petroleum tax regime
All upstream petroleum activity on the Norwegian Continental Shelf (NCS) is taxable to Norway.Taxation is based on net income at a marginal tax rate of 78%, which comprises the ordinary 22% CIT rate and a 56% special tax. All income is subject to 22% CIT, while only income from offshore production and pipeline transportation of petroleum on the NCS (offshore tax regime) is subject to the additional 56% special tax.
Following the 2022 shift to a ‘sequential’ tax system, tax on upstream petroleum tax activities is calculated in two steps. Firstly, the tax in the ordinary 22% tax base is calculated. The resulting tax amount is then deducted from the special tax base, on which a ‘technical special tax rate’ of 71.8% is applied in order for the overall effective tax rate to remain 78%: