Date: 2025-10-16Category: Not ApplicableState: Union GovernmentCountry: Europe
Council Decision (EU) 2025/2094 of 10 October 2025 authorising the opening of negotiations with the Kingdom of Norway for an agreement on administrative cooperation in the field of direct taxation
**Executive Summary**
Council Decision (EU) 2025/2094, dated October 10, 2025, authorizes the European Commission to open negotiations with the Kingdom of Norway for an agreement on administrative cooperation in the field of direct taxation. The goal is to broaden the scope of cooperation in taxation between the EU and Norway. The Commission must consult and regularly report to the Working Party on Tax Questions throughout the negotiation process.
**Key Points / Main Content**
* **Negotiation Authorization:**
* The Commission is authorized to open negotiations with Norway for an agreement on administrative cooperation in direct taxation.
* Negotiations are based on the Council's negotiating directives, which can be revised as needed.
* **Negotiation Process:**
* Negotiations will be conducted in consultation with the Working Party on Tax Questions.
* The Commission will regularly report to the special committee (Working Party on Tax Questions) on progress and consult on a regular basis.
* The Commission must report to the Council on the conduct and outcome of the negotiations when requested.
* **Scope of Agreement:**
* The agreement aims to broaden the scope of reciprocal automatic exchange of information between Member States and Norway, as per Directive 2011/16/EU.
* It will also broaden tax recovery assistance, covering all taxes beyond those already covered in the existing agreement related to value-added tax, aligning with Council Directive 2010/24/EU.
**Impact Analysis**
**European Commission**
* *Impact:* Responsible for conducting negotiations with Norway and reporting on progress.
* *Action Required:* Open negotiations, consult with the Working Party on Tax Questions, regularly report on progress, and inform the Council when requested.
**Member States**
* *Impact:* Benefit from the broadened scope of administrative cooperation in direct taxation and tax recovery assistance with Norway.
* *Action Required:* N/A
**Kingdom of Norway**
* *Impact:* Subject to negotiations with the EU to expand administrative cooperation in direct taxation.
* *Action Required:* Engage in negotiations with the Commission to reach an agreement.
**Working Party on Tax Questions**
* *Impact:* Designated as the special committee for consultation during negotiations.
* *Action Required:* Consult with the Commission on the negotiation process and provide feedback.
Key Entities Referenced
Kingdom of Norway: A key trade partner of the Union involved in administrative cooperation negotiations.
Council Directive 2011/16/EU: EU Directive on administrative cooperation in the field of taxation.
European Commission: Authorized to open negotiations with Norway regarding direct taxation.
Working Party on Tax Questions: Special committee designated to consult on negotiations with Norway.
Official Journal EN
of the European Union L series
2025/2094 16.10.2025
COUNCIL DECISION (EU) 2025/2094
of 10 October 2025
authorising the opening of negotiations with the Kingdom of Norway for an agreement on
administrative cooperation in the field of direct taxation
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular Article 115, in conjunction with
Article 218(3) and (4) thereof,
Having regard to the recommendation from the European Commission,
Whereas:
(1) The Member States benefit from a solid and well-integrated framework of administrative cooperation in the field of
direct taxation laid down in Council Directive 2011/16/EU(1). That framework aims to ensure tax compliance within
the Union while assisting tax authorities in preventing and tackling tax fraud, evasion and avoidance.
(2) The Kingdom of Norway (‘Norway’) is a key trade partner of the Union and a contracting party to the Agreement on
the European Economic Area(2). It is in the interest of the Member States to broaden the scope of the framework of
cooperation in the field of taxation between the Union and Norway, which is currently limited to the field of value
added tax.
(3) To that aim, negotiations should be opened with a view to concluding an agreement on administrative cooperation
in the field of direct taxation with Norway, which would broaden the scope of reciprocal automatic exchange of
information between the Member States and Norway, by covering the exchange of information as referred to in
Article 8(1) and Articles 8a and 8ab of Directive 2011/16/EU.
(4) The negotiations should also aim to broaden the scope of tax recovery assistance between the Member States and
Norway, by covering claims relating to all taxes besides those already covered by the Agreement between the
European Union and the Kingdom of Norway on administrative cooperation, combating fraud and recovery of
claims in the field of value added tax(3), in line with Council Directive 2010/24/EU(4),
HAS ADOPTED THIS DECISION:
Article 1
1. The Commission is hereby authorised to open negotiations for an agreement on administrative cooperation in the
field of direct taxation with the Kingdom of Norway.
2. The negotiations shall be conducted on the basis of the negotiating directives of the Council set out in the addendum
to this Decision. Those negotiating directives shall be revised and further developed as appropriate depending on the
evolution of the negotiations.
Article 2
1. The negotiations shall be conducted in consultation with the Working Party on Tax Questions, which is hereby
designated as the special committee provided for in Article 218(4) of the Treaty on the Functioning of the European Union.
2. The Commission shall regularly report to the special committee referred to in paragraph 1 on the steps undertaken
pursuant to this Decision and consult it on a regular basis.
(1) Council Directive 2011/16/EU of 15 February 2011 on administrative cooperation in the field of taxation and repealing Directive
77/799/EEC (OJ L 64, 11.3.2011, p. 1, ELI: http://data.europa.eu/eli/dir/2011/16/oj).
(2) OJ L 1, 3.1.1994, p. 3, ELI: http://data.europa.eu/eli/agree_internation/1994/1/oj.
(3) OJ L 195, 1.8.2018, p. 3, ELI: http://data.europa.eu/eli/agree_internation/2018/1089/oj.
(4) Council Directive 2010/24/EU of 16 March 2010 concerning mutual assistance for the recovery of claims relating to taxes, duties
and other measures (OJ L 84, 31.3.2010, p. 1, ELI: http://data.europa.eu/eli/dir/2010/24/oj).
ELI: http://data.europa.eu/eli/dec/2025/2094/oj 1/2EN
OJ L, 16.10.2025
3. Whenever so requested by the Council, the Commission shall report to the Council on the conduct and the outcome
of the negotiations, including in writing.
Article 3
This Decision is addressed to the Commission.
Done at Luxembourg, 10 October 2025.
For the Council
The President
S. LOSE
2/2 ELI: http://data.europa.eu/eli/dec/2025/2094/oj