The Ministry of Finance has outsourced the evaluation of national transparency requirements to one of the "Big Four" accounting firms - Deloitte. PWYP Norway shares its consultative input with notes.
The accounting firm proposes to divide the entire regulatory framework without explaining the benefits of doing such a change (or whom would benefit from this change).
The report does not evaluate and cannot evaluate the purpose of making tax adjustments visible because the mechanism which could do it, is still is not in place.
Read PWYP Norway's consultative input (in Norwegian): Finansdep_horingsbrev_LLRevalueringenDeloitte_PWYPNorge09NOV2017.pdf
PWYP Norway believes that there is no need to differentiate between the regulations for making payments to authorities visible versus the regulations for making unwanted tax adjustment visible - these regulations are already separated.
Consultative letters, hearing notes, consultative bodies and all consultative responses are available on the Ministry of Finance's website here. (in Norwegian)
This can be done a lot easier. PWYP Norway's recommendation to the Ministry of Finance is clear: stop messing around, make the reporting obligation pursuant to §4, section 3, independent of the materiality limit in §4, section 2. If it is desirable to have more companies reporting on extended country-by-country rules, set out the regulations for all companies over the materiality limit, asking the extraction and forest companies to report one additional number beyond what everyone else must report: production. This will make unwanted tax adjustment visible and ensure that there is only one regulatory framework to deal with.
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