Proposed cut of tax requirement for cross-border re-structurings

22 September, 2021

Today, on 22 September 2021, it was proposed to make an important change to the Norwegian rules on tax exempt cross-border restructurings (mergers, de-mergers and exchange of shares).

The announcement may be read here (in Norwegian only):

The proposal in a nutshell:

-The current requirement on tax continuity in the foreign company is suggested to be removed.

-The reason is that this condition is hard to meet. The proposal is expected to simplify the crossborder restructuring processes. Without having major impact on the Fiscal budget, as tax continuity will still be required for the Norwegian companies and owners. (The fiscal loss may be limited to the lost advantage of levying immediate tax on unsuccessful transactions).

-The change will apply to mergers etc. between Norwegian and foreign companies.

-The other requirements must still be met.

The deadline for comments is 22 December, 2021.

We strongly support this proposal.

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