On 16 March 2016, the Norwegian Ministry of Finance published draft amendments to provide for specific provisions for corporate residency with effect from the 2018 fiscal year. Currently, corporate residence is not defined under Norwegian tax law, but companies are generally treated as resident in Norway if incorporated in Norway or if effective management and control is in Norway.
The draft amendments would amend paragraph 1 of Section 2-2 of the Tax Act to provide that companies will be subject to tax if established in Norway or with effective management in Norway. However, this would not apply to companies resident in jurisdiction with which Norway has a tax treaty. The Tax Administration Law would also be amended to reflect the changes in the Tax Act.
Click the following link for the consultation page (Norwegian language). Comments are due by 16 June 2017.
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