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). …