On 3 October 2006, the Directorate of Taxes made some amendments to the current CFC rules (Regulation of 19 November 1999 No. 1158). The amendments apply from 1 January 2007. Details of the amendments are summarized below.
CFC legislation
Under the CFC legislation, if a foreign company is owned or controlled, directly or indirectly, for at least 50% by Norwegian taxpayers, its profits, whether or not distributed, are attributed proportionately to its No…