Time limits for going to court for tax paid in error – reclaim of Norwegian dividend tax

On 19 October 2006, the Norwegian Supreme Court gave its decision in two similar cases concerning the issue as to whether a statute of limitations applies to claims for damages under civil law on the ground that a tax assessment was wrong because the EEA Agreement was not properly implemented (Edquist case (HR-2006-01795-A, Case No. 2006/543) and Canica case (HR-2006-01796-A, Case No. 2006/1284)).

(a) Background. In 1994, the EEA Agreement was concluded between…