Skattlegging av digitale tjenester

13 June 2022 11:56

Skattlegging av digitale tjenester

Master thesis by Marcus Andersen Holte and Sander Sivertsvoll.

Marcus Andersen Holte (left) and Sander Sivertsvoll.

This master thesis addresses the topic of digital services tax (DST). The goal of such tax is to ensure that income from digital services is taxed where value is created, instead of only where companies choose to allocate profit. As of December 2021, 8 European countries have introduced a DST. The most common feature of the tax is that it is levied on income from digital marketing and from digital interfaces that connect buyers and sellers. The tax is only applicable to companies with a global turnover exceeding a certain threshold, typically 750 million euros.

Our estimates show that introducing a DST in Norway would affect 27 multinational companies and provide an annual tax revenue of about NOK 200 million at a tax rate of 3%. In reality, the proceeds will most likely be higher, as the thesis focuses on estimating a lower bound. The reason we consider this as a lower bound is that the actual size of the companies' digital revenues in Norway tends to be higher than the amount reported through the Norwegian branch.

The main findings from our thesis are summarized below.

  • Norway's tax revenue from a DST would have been at least NOK 219 million in 2020. This amounts to approximately 0.23% of the total revenue from corporate taxes.
  • Other European countries that have introduced a DST have received tax revenues that amount to between 0.56% and 3.19% of their corporate tax revenues.
  • 27 large, digital companies will be eligible to DST in Norway under the main assumptions of the thesis. Out of these, Schibsted is the only Norwegian company.
  • 12 of the eligible companies do not pay any corporate income tax in Norway today. For the remaining companies, we find indications that several of these understate their actual revenue, and thus do not pay their fair share of corporate income tax in Norway.
  • In conclusion, a DST will provide only a modest increase in tax revenue, but accurately target large, digital companies

Holte, Marcus Andersen, and Sander Sivertsvoll: Skattlegging av digitale tjenester: Hva er virkningene av å innføre en digital omsetningsavgift i Norge? Master Thesis, NHH, 2021.