Executive summary
On 22 September 2021, the Norwegian Ministry of Finance (the Ministry) issued a public consultation paper proposing amendments to the conditions for a tax neutral cross-border restructuring.
The current rules provide for the possibility of carrying out a cross-border restructuring, including mergers, demergers and certain exchanges of shares, without triggering Norwegian taxation on a company or shareholder level, subject to certain conditions. One of the general conditions is t…