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Norway

Americas

Norway’s challenge to intercompany loan margins for ConocoPhillips and Exxon

April 11, 2022

New York City Economist Dr. J. Harold McClure analyzes why the Norwegian tax authority’s recent wins in the Exxon and ConocoPhillips litigations highlight the role of carefully examining the market evidence provided by various databases of loan margin data.

Austria

Recent corporate tax trends in EU countries: Cristina Enache / Tax Foundation→

April 5, 2022
Europe

Swedish Administrative Court of Appeal did not consider multiple-year data, adjusted the taxable result

January 26, 2022

Emiliha Ferrão, Censio Tax, discusses Sweden’s Administrative Court of Appeal’s November 2021 ruling in favor of the Swedish Tax Authority in a case involving a change of transfer pricing methodology and a restrictive use of multiple-year results to support . . .

Americas

OECD countries’ tax revenues fell in 2020, but less than their GDPs

December 6, 2021

The ratio of tax revenues to GDP in OECD countries rose slightly in 2020 amid the Covid-19 pandemic, as nominal tax revenues generally fell but did so at a lower rate than countries’ GDPs, according to the OECD’s 2021 annual revenue statistics released December 6; corporate income tax revenues . . .

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

November 23, 2021

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Europe

Norway proposes important changes to rules on tax-free cross-border reorganizations

November 2, 2021

Sander​ Pettersen, CMS Kluge Advokatfirma AS, discusses the Norwegian Ministry of Finance’s September 3 release of a proposal to simplify cross-border mergers, demergers and share exchanges to facilitate . . .

Americas

ICAP multilateral tax risk assurance program applications due September 30

September 2, 2021

Multinational entities interested in participating in the first full round of the OECD Forum on Tax Administration (FTA) International Compliance Assurance Programme (ICAP) have until September 30 to submit the . . .

Africa

Countries take diverse transfer pricing approaches to financial transactions, profit attributions

August 4, 2021

Updated transfer pricing country profiles released by the OECD on August 3 include for the first time information on 20 reviewed countries’ transfer pricing rules applicable to . . .

Europe

Iceland, Liechtenstein, Norway tax-related state aid investigations close

June 9, 2021

Investigations into the tax-ruling practices of Iceland, Liechtenstein, and Norway have found no evidence of the countries’ tax rulings being used in violation of state aid rules, according to a June 4 . . .

Austria

How will the European Commission define shell companies to stop tax avoidance?

June 7, 2021

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021
Europe

Norway’s oil lobby sharply criticizes plans to more than triple CO2 tax: Nora Buli & Nerijus Adomaitis / Reuters→

January 12, 2021
Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

OECD
Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020
Asia-Pacific

China seeks tax treaty with Norway, official says: Ministry of Foreign Affairs of the People’s Republic of China→

September 1, 2020
Europe

Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute

June 17, 2020

Michael Vorndran, Nord Advisory AS, Oslo, Norway, discusses a May 28 decision of the Norwegian Supreme Court in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office . . .

Asia-Pacific

Synthesized text of Australia-Norway tax treaty as modified by BEPS MLI published:  Australian Taxation Office→

May 13, 2020
Europe

Norway adjusts loss carryback and VAT rules, postpones tax payments, in response to COVID-19: KPMG→

March 19, 2020
Europe

Norway proposes new withholding tax on some related-party payments

March 11, 2020

Michael Vorndran of Nord Advisory AS, Oslo, discusses a Norway Ministry of Finance proposal, issued on February 27, for a 15% withholding tax on interest, royalty, and lease payments to non-resident related parties. . . .

Digital Economy

Norway Finance Minister to introduce digital tax if 2020 international solution fails: Mari Brenna Vollan / Klassenkampen (in Norwegian)→

January 13, 2020
Africa

Shell publishes country-by-country tax report

December 22, 2019

Oil giant Royal Dutch Shell on December 17 published its country-by-country report data for 2018 on the internet, providing . . .

Asia-Pacific

Switzerland’s Federal Council approves amendments to tax treaties with New Zealand, Netherlands, Norway, Sweden

November 6, 2019

Switzerland’s Federal Council on November 6 approved four tax treaty protocols . . .

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Asia-Pacific

Norway disallows Telenor losses claimed upon settlement Indian subsidiary’s bank guarantees: Reuters→

August 26, 2019
Europe

Multilateral tax treaty to enter into force for Norway

July 29, 2019

The OECD today announced that Norway has deposited its instrument . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Europe

Intragroup IP transfer was undervalued for tax purposes, Norway appeals court rules

April 2, 2019

Pilar Barriguete and Edland Graci of Duff & Phelps, Spain, discuss an interesting March 19 Norwegian appellate court decision which concluded that the “relief from royalty” valuation method should not have been used to determine the value of an intangibles transfer in a merger and acquisition transaction involving Dynamic Rock Support AS . . .

Americas

US tax officials discuss coming country-by-country reporting guidance, treaties, other initiatives

December 19, 2016

The US intends to release tax guidance on country-by-country reporting for MNEs that addresses reporting for LLCs in US groups and for tiered partnerships, officials said at a December 15-16 tax conference. Officials also discussed just-released final regs on outbound transfers of goodwill, US tax treaty negotiations, and the pending EU State aid. . . 

Europe

Norway State Budget 2019 includes unexpected tax rate reduction, stricter interest deductibility rules

October 16, 2018

Michael Vorndran, a principal with Nord Advisory AS, Oslo, Norway, discusses the Norwegian 2019 state budget, released last week, which contains a number of proposed tax changes that will be of significance to companies in Norway . . .

Europe

MNEs in EU pay lowest effective tax rate in Luxembourg (2.2 %), highest in Norway (48.7%), study says: EU Parliament, Greens/EFA Group→  

January 23, 2019
Europe

Norway considers more interest deduction limits: Deloitte→

May 8, 2017
Asia-Pacific

Tax agreements between Hong Kong and Nordic countries enter into force

March 2, 2016

Hong Kong’s Inland Revenue Department on March 2 announced the entry into force of tax information exchange agreements with Denmark, the Faroe Islands, Iceland, Norway, Sweden, and . . .

Americas

OECD publishes updated transfer pricing profiles for 14 countries

April 9, 2018

The OECD today published transfer pricing profiles for Australia, China, Estonia, France, Georgia, Hungary, India, Israel, Liechtenstein, Norway, Poland, Portugal, Sweden, and Uruguay. The profiles

Africa

US has agreed to country-by-country tax info exchange with 11 countries, OECD says

June 22, 2017

The United States has so far put in place 11 bilateral competent authority arrangements for the automatic exchange of country-by-country reports, the OECD reported a June 22 release. The US now has . . .

Europe

OECD and Norway pledge funds to help developing countries improve tax systems

September 10, 2018

The OECD and Norway have together pledged to donate EUR 4.6 million (USD 5.3 million) over 4 years to . . .

Europe

Norway proposes to amend tax residency rules: EY→

March 22, 2017

See: EY.

Asia-Pacific

Feedback sought in review of 8 countries’ tax dispute resolution processes

June 10, 2017

The OECD on June 9 asked multinational firms to provide feedback regarding their experiences with the tax dispute resolution processes in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore and Spain. The eight countries’ mutual . . .

Asia-Pacific

OECD publishes reports covering cross-border tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

March 13, 2018

The OECD today published reports approved by the “Inclusive Framework on BEPS” which assess tax dispute resolution practices in the Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, and Spain. As members . . .

Posts navigation

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What’s Next

May 19 – 20Tax Council Policy Institute ConferenceWashington, D.C.
May 19 – 20IFA Second European Region ConferenceMilan, Italy
May 24IFA Webinar Series Pillar Two: An UpdateVirtual Event
Sept. 4 – 8IFA CongressBerlin
Add Your Event
RECENT COMMENTS
  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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More than 300 international tax and transfer pricing experts from around the the world have published with MNE Tax. You can find listing of our authors below:

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Latest

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022
  • Finnish Tax Administration to Publish Guidance on Reverse Hybrid Legislation
    June 28, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • UK delays Pillar 2 of global tax rules to December
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022
  • Mutual Agreement Procedures (MAP) and Tax Treaties benefit grant General Rules under public consultation in Dominican Republic
    June 21, 2022

Recent Comments

  • Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024
  • Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024
  • David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023
  • Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023
  • Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

R&D Tax Credit News

  • Muddled goals, broad scope lead to unexpected costs of OECD tax agreement
    April 20, 2022
  • US House of Representatives Ways and Means Committee Republicans reintroduce R&D-related legislation: Committee on Ways and Means→
    April 20, 2022
  • Irish Department of Finance seeks public comments by May 30 on research & development (R&D) tax credit and the `Knowledge Development Box,’ an OECD-compliant intellectual property regime, which provides relief from corporation tax on income arising from qualifying assets, such as computer programs and inventions protected by a qualifying patent: Irish Ministry of Finance→
    April 18, 2022
  • What does the Marijuana Opportunity Reinvestment and Expungement Act mean for the R&D tax credit?
    April 7, 2022
  • South Africa’s R&D Catch-22: Lydia Clowney / CrossBorder Solutions→
    April 6, 2022

Accounting & Reporting News

  • Calls are increasing for company disclosures on tax to help build public trust and fit in with environmental, social and governance (ESG) agenda: Aidan Lucey / The Irish Times→
    April 20, 2022
  • Will Amazon’s investors make the rules on tax transparency more clear?: CrossBorder Solutions→
    April 13, 2022
  • US Senate Finance Committee Chair Ron Wyden requests pharmaceutical company Merck explain its tax accounting practices, as it reports just 14% of pretax income in the US despite US market being home to 46% of global sales: Ron Weyden / US Senate Committee on Finance→
    April 5, 2022
  • UK Supreme Court holds on the tax deductibility of employee share options required under IFRS 2
    March 29, 2022
  • Annual vs. quarterly provision: Howard Telson / CrossBorder Solutions→
    March 23, 2022

Transfer Pricing News

  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Evolution of Transfer Pricing in Saudi Arabia
    June 23, 2022
  • The Functional Analysis—What You Need to Know
    June 22, 2022
  • How International Organizations are Changing Transfer Pricing Compliance
    June 22, 2022
  • The OECD’s Tax Transparency in Africa 2022: Africa Initiative Progress Report
    June 22, 2022

US tax focus

  • Policy Paper: Transfer pricing documentation
    July 26, 2022
  • Indonesia Taxes Crypto Asset Transactions
    July 12, 2022
  • New CbC Reporting Requirements to Apply in Kenya
    July 7, 2022
  • The Colombian National Tax and Customs Administration (DIAN) modified 2021’s Resolution 164 related to the Ultimate Beneficial Owner´s Report (RUB).
    July 5, 2022
  • Frustrated with Congress, Intel delays chips groundbreaking ceremony
    June 28, 2022

Trending Now

  • Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice by Andrew Hickman | posted on January 13, 2021
  • OECD officials note disagreement over digital tax update, reveal plans for tax and transfer pricing guidance by Julie Martin | posted on May 4, 2020
  • US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure by Elisa Kaminsky | posted on May 13, 2020
  • How prudent is it to conduct transfer pricing risk adjustments for captive cost centres? by Smarak Swain | posted on May 4, 2021
  • OECD lists countries agreeing to country-by-country reporting exchange by Staff | posted on May 4, 2017
  • Nike’s transfer pricing state aid dispute: the underlying issues by Dr. Harold McClure | posted on July 19, 2021
  • Return on assets (ROA) is an unreliable profit indicator by Ednaldo Silva | posted on October 2, 2019
  • The economics of leasing and the arm’s length standard by Dr. Harold McClure | posted on October 9, 2020

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Copyright © 2021. DISCLAIMER: The information provided herein is general and may not be applicable in all situations. It should not be acted upon without legal advice accounting for a particular situation.