Executive summary
In connection with the revised national budget for 2020, the Norwegian Ministry of Finance, on 12 May 2020, issued an interpretation statement concerning the application of the statutory general anti-abuse rule (GAAR) on tax-exempt “de-merger sales” of shares. A de-merger sale generally implies that a single asset may be sold through a tax-free demerger and a subsequent tax-exempt sale of the share in a spun-off company. Based on its understanding of the 2014 Supreme Court …