The reference is 2/3 of  our domestic rate. Domestic CIT rate is currently 22%. Triggering rate: 14,67%.

Definition of Low-tax jurisdictions: Low-tax jurisdictions are jurisdictions in which the ordinary income tax on the overall profit of the company or undertaking is less than two thirds of the tax that would have been levied on such company or undertaking if it had been resident in Norway. The Norwegian CIT rate in 2025 is 22%.

The assessment include a comprehensive evaluation of the tax rules applicable to the specific type of entity in question. Considerations  include special tax regimes, differences in deduction rules, variations in depreciation rates, and tax incentives.