The Norwegian Tax Administration has published a 2018 ruling concerning the carry forward of losses following a demerger that was performed as part of an agreement to discontinue cooperation between certain parties. In general, if the primary motive of a restructuring, such as a demerger, was the utilization of the loss carryforward, then such utilization may be denied. Where the primary motive is a business motive, then the utilization of the loss carryforward should be allowed. In the ruli…