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Immediate economic measures in response to the outbreak of the coronavirus

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On Friday 13 March 2020, the Government proposed a series of urgent measures to reduce the financial consequences of the ongoing coronavirus outbreak (COVID-19). Below are the details. Note that these proposals will be considered by the Parliament and that there may be changes. The Government also reports that this is the first phase of a series of measures that will be taken. Below you will also find news from The Central Bank of Norway and The Financial Supervisory Authority of Norway. 

This article is updated as of 14 March 2020, 10:00 am CET.

Corporate Tax

Temporary retroactive deduction of tax losses

The Government has proposed to introduce temporary access to reverse tax losses in 2020 against taxed profits for the previous two years. Such a measure was also introduced during the financial crisis in 2008. 

The scheme is intended to help companies suitable to make a profit, but which due to the outbreak of the coronavirus will not be able to make a profit in 2020. 

Since the scheme only covers companies that made a profit in 2018 or 2019, this will prevent companies that are not suited to generate a profit,  or do not conduct business, to have the opportunity to claim the special rule.

According to the proposal, the companies will be paid an amount corresponding to the tax value of the loss carried forward against previous years' profits (with interest at ordinary rates). The tax value of the loss will only be paid out at the tax statement in 2021. 

The Ministry has proposed a limit on the amount of NOK 30 million for the return of the tax losses for 2020. The limit is intended to ensure that most small and medium-sized companies with deficits this year and profits from previous years will benefit from the initiative.

Deferred payment of advance tax and wealth tax

In order to address the liquidity challenges that several businesses will now face, it has been proposed that owners of deficit companies should be able to defer payment of wealth tax. Such a scheme reduces the need to pay dividends in companies that run deficits to cover the owners' wealth tax. The proposal will apply to business assets for the tax year 2020 for personal taxpayers who have an accountable business with a negative annual result in 2020. 

The scheme allows the taxpayer to apply for a one-year deferred payment of the wealth tax for the 2020 tax year when it falls due for payment 2021. 

If the taxpayer makes a loss in 2020, there will be grounds for applying for exemption from payment of withholding tax or withholding tax for business assets in 2020.

Pension

During a pandemic situation, it is very important that the public health sector can provide necessary health care. A large number of sick people will require increased staffing, and the government now wants to facilitate the mobilization of qualified personnel. It is assumed that such mobilization could occur through voluntary recruitment and possibly ordering. 

In addition, the Ministry assumes that the proposed schemes shall apply correspondingly to persons receiving pensions from municipal occupational pension schemes that are not covered by the laws mentioned above. 

Under current schemes, income from work can lead to a reduction or loss of pensions, which it is feared will make it less interesting for old-age pensioners to sign up for voluntary service. It is therefore proposed to suspend the rules on shortening and cancellation of pensions on specified terms and for a limited period. 

The suspension assumes that the service is necessary to meet a personnel need caused by the outbreak of coronavirus.

Competence

Digitization and robotisation require new competence, and the raising of skills in the workforce has therefore been and is a major challenge for many companies. By increasing the support for competence raising and corporate training during a period of lower activity, this tool can be very beneficial in a social perspective in the longer term as this will strengthen both employers and employees. 

The support is intended to be organized through increased grants to the county authorities to meet regional needs.

Increased grants to municipalities

The Government has signaled that increased appropriations of discretionary funds will be given to municipalities that have had significantly more expenses in connection with the outbreak of the virus. In total, the package is estimated at NOK 250 million.

Indirect airline taxes are temporarily removed

The travel industry and especially aviation are severely affected by the virus outbreak. The Government therefore proposes to remove the air passenger tax to the government and the take-off charge, the passenger charge and the security charge to Avinor AS. 

The Ministry of Finance proposes to lift the indirect airline taxes for all flights from 1 January 2020 to 31 October 2020. 

The primary purpose of the indirect airline taxes is to obtain revenue from the government, but it can also have an environmental impact by reducing the number of flights. The Ministry of Finance does not expect this proposal to have a particular impact on the volume of flights during the period, where the contagion considerations will have the greatest impact. With this measure, the Ministry of Finance therefore wants to provide temporary relief for the airlines. 

According to the parliament's decision on air passenger tax, there is a tax per passenger on all departures from Norwegian airports. There is a low rate (NOK 76.50) for travel with a final destination in Europe and a high rate (NOK 204) for travel to other final destinations. The airline is responsible for the duty. The airlines must, themselves or through a representative, be registered with the tax authorities as a taxable person. The tax is payable to the government by the 18th of the month after the tax obligation arose. Since it is now proposed to lift the tax from 1 January this year, this means that the airlines have paid the fee for January and possibly February. It therefore follows from the proposal that the taxes paid this year will be reimbursed. The Ministry of Finance will in regulations provide for such repayment. The Government's revenue loss is estimated at NOK 1,560 million. 

It is irrelevant to the fee when the air ticket is purchased, and from November 1, 2020, flights will again be subject to air passenger tax. 

The airlines also pay fees to Avinor AS. This applies to the take-off charge, the passenger charge and the security charge and is regulated in separate regulations laid down by the Ministry of Transport and Communications. The fees go towards financing the airports and the security services. With effect from today, the Ministry will exempt airlines from the obligation to pay airport fees to Avinor. The exemption will be effective until 30 June 2020. Since the fees are paid on an ongoing basis, the changes will only take effect in the future. 

The fees amounted to approximately NOK 3.8 billion in revenue for Avinor in 2019, and the measure is intended to help the airlines in a demanding financial situation.

Changes from The Central Bank of Norway

In addition to the Government's measures, The Central Bank of Norway has today decided to make an interest rate cut of 0.5 percentage point entailing that the key policy rate is reduced to 1.0 per cent to mitigate the expected negative financial implications of the virus outbreak. In order to ensure that the key policy rate is reflected in money market rates, The Central Bank of Norway has also decided to add liquidity to the banking market by offering an extraordinary three-month F-loan to banks. As a countercyclical measure, the Central Bank of Norway also advised the Ministry of Finance to ease the banks capital adequacy requirements to enable the banks to more freely lend money to companies in need of external financing. 

Postponement with payment of advance tax

For many, the advance payment of  tax falls into 4 installments. The first term March 15th. The government has approved a preliminary deferral until 1 May. This will primarily apply to self-employed persons, but also others who pay advance tax, eg due to wealth will be included. For the other terms, there is so far no change.

Reporting Deadlines

As a result of the coronavirus, the Financial Supervisory Authority of Norway has decided to grant general time limits for certain reports. The following is taken from their website: 

Reporting deadlines deferred as of 13.03.2020 

  • Reporting by banks on industrialized losses (KRT-1131): Deadline for reporting is postponed to 31 March 2020 
  • Reporting from payment service providers on fraud reporting (KRT-1132): Deadline for reporting is postponed to March 31, 2020 
  • Reporting for companies that conduct insurance brokerage (KRT-1007): Deadline for reporting is postponed to March 31, 2020. 

See separate blog post about new immediate financial measures in response to the outbreak of the coronavirus. 

                                                                      ***

This blog post is written by Erik Stenvik Granly, Kjetil Øpstad, Anni Haugen, Ida Solberg Henning, Torbjørn Stokke and Ståle Wangen. 

Ståle Wangen

Ståle Wangen

Jeg heter Ståle Wangen og jobber som advokat i Advokatfirmaet PwC. Jeg leder PwC Norges avdeling for internasjonal skatt og jobber til daglig med å bistå norske og utenlandske virksomheter med skatteplanlegging, strukturering av kjøp og salg av virksomheter, internprising og andre spørsmål knyttet til bedriftsbeskatning i Norge og utlandet. Jeg har mer enn 20 års erfaring med skatterådgivning.

Skatteverdenen blir stadig mer internasjonal og kompleks. Ved kjøp og salg av varer og tjenester utenfor Norges grenser må norske virksomheter håndtere skatteregler både i utlandet og i Norge. PwC har kontorer i de fleste land og vi har et unikt nettverk av skatterådgivere som kan bistå med spesialkompetanse på de fleste områder. Jeg håper mine innspill kan gi deg en alternativ innfallsvinkel til ulike temaer enn hva tradisjonelle nyhetsbrev gir.

Ta gjerne kontakt dersom du har spørsmål, kommentarer eller innspill.

My name is Ståle Wangen and I work as a partner and lawyer in PwC Tax and Legal Services in Oslo. I am head of PwC Norway’s international taxation services, and I have more than 20 years of experience assisting Norwegian and foreign businesses with tax planning, cross border restructuring, mergers and acquisitions (M&A), transfer pricing and other issues related to corporate taxation

Tax world is becoming more international and complex. Norwegian companies must increasingly handle tax rules abroad. PwC has offices almost all over the world and we have a unique network of tax advisors who can assist with expertise in most areas.

Please feel free to contact me if you have any questions, comments or input.

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