Norway proposes new rules for cross-border reorganizations and exit taxation
April 28, 2011On 25 March 2011, the Norwegian Ministry of Finance presented a White Paper on tax-free cross-border reorganizations based on continuity in tax values/basis.
The Norwegian Ministry of Finance proposes to establish by law that certain cross-border reorganizations can be carried out tax-free based on tax continuity, namely:
- Mergers/demergers (divisions)
- Share-for-share exchanges (share swaps)
- Migration of corporate tax residence
- Intra-group transfer of assets, etc. (incorporation of branches, etc.)
The proposed rules on tax-free share-for-share exchanges and intra-group transfers of assets, etc., apply to reorganizations both within and outside the European Economic Area (EEA).
The rules do not apply to companies in low-tax countries, and wholly artificial low-taxed companies within the EEA, taking part in the reorganization.
Further details are available from the Ernst & Young International Tax Alert which can be accessed using the link below:
Related content
The Budget for 2013–14 was presented to Parliament by the Minister of Finance on 22 February 2013. Details, which, unless otherwise indicated, will apply from 1 …
On 6 December 2012, the President issued the following decree-laws, which were published in the Official Gazette No. 49.a: Decree-Law 101 for 2012 relating to the …
On 20 October 2013, the Minister of Finance and Economy presented the 2013 Budget Bill to Parliament. The key tax proposals in the draft budget …
On 11 November 2012, the Draft Finance Law for 2013 was adopted by the National Assembly. The most important features, which will generally apply from 1 …
Loading ...