The Resource New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement

New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement

Label
New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement
Title
New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement
Creator
Subject
Language
eng
Summary
This article provides an overview of the new Norwegian tax rules for cross-border restructurings and comments on the compatibility of the new rules with the fundamental freedoms in the agreement of the European Economic Area. It is submitted that certain aspects of the new rules may create an unjustified restriction on the right of establishment and the free movement of capital. In particular this may apply to the exclusion of triangular mergers and demergers from the scope of application of the new rules, the termination of the right to utilize previous tax losses after the merger or demerger (in certain situations), the tax treatment applicable to inventory and intangibles taken out of the Norwegian tax jurisdiction and the introduction of the wholly artificial requirement as a measure to prevent tax abuse for cross-border mergers and demergers
Citation source
In: Intertax. - Alphen aan den Rijn. - Vol. 39 (2011),
http://library.link/vocab/creatorName
Scapa Passalacqua, A.B
Geographic coverage
Europe
Language note
English
http://library.link/vocab/subjectName
  • cross-border reorganization
  • fundamental freedoms
  • triangular merger
  • demerger
  • EEA
Label
New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement
Instantiates
Publication
Label
New tax rules on cross-border mergers and demergers in Norway and their compatibility with the EEA agreement
Publication

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