The Norwegian Ministry of Finance issued an interpretation notice on 2 march 2015, clarifying its position on whether a tax exempt shareholder is considered when determining if the Norwegian ownership threshold is met for the purpose of applying the country's controlled foreign company (CFC) rules.
Norwegian CFC rules apply if at least 50% of a company resident in a low-tax jurisdiction is owned or directly or indirectly controlled by Norwegian resident taxpayers (corporate or individual). Based on this wording, some interpreted the rules to mean that only a taxable participant should be considered when making the assessment of whether Norwegian control exists. However, in its interpretation, the Ministry holds that both taxable and non-taxable participants are to be considered when making the control assessment.
Click the following link for the interpretation as issued by the Ministry of Finance (Norwegian language).
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