Norway proposes new rules for cross-border reorganizations and exit taxationApril 28, 2011
On 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: