NORWAY

On January 18, 2010, the Norwegian Ministry of Finance released a discussion paper that, if adopted, would significantly increase the opportunities for cross-border reorganizations. The general impression of the proposal is that it entails a liberalization and simplification of the rules governing c...

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Bibliographic Details
Published inJournal of International Taxation Vol. 21; no. 4; p. 18
Main Authors Hareide, Steinar, Kvarme, Hanne F, Sandvik, Eyvind
Format Trade Publication Article
LanguageEnglish
Published Boston Thomson Reuters (Tax & Accounting) Inc 01.04.2010
Subjects
Acquisitions & mergers
Business operations
Cross border transactions
International taxation
Jurisdiction
Limited liability companies
Proposals
Stockholders
Tax basis
Tax free reorganization
Taxation
Norway
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Summary:On January 18, 2010, the Norwegian Ministry of Finance released a discussion paper that, if adopted, would significantly increase the opportunities for cross-border reorganizations. The general impression of the proposal is that it entails a liberalization and simplification of the rules governing cross-border reorganizations. Further, if adopted, the proposed changes would bring the Norwegian tax law further in line with Norway's obligations under the European Economic Area (EEA) agreement. Under Norwegian tax law, a merger or demerger is generally treated as a disposal of the shares and underlying assets, which can lead to capital gains taxation, recapture of depreciation, and restrictions on loss carryforwards. However, under certain conditions, mergers and demergers can be done tax free on a rollover basis.
ISSN:1049-6378