Norway is keen to implement the OECD's BEPS Project into its legislation and has undergone a number of changes as a result. The Ministry of Finance has clearly signalled that the various Action Points will be implemented by 2017 and proposals are expected later in 2016.
"There seems to be a political willingness to implement measures. When the OECD has hammered it out, Norway will likely implement it pretty quickly," said Sverre Hveding, head of tax at Selmer. "It is fair to say that most tax lawyers involved in international tax are very into what is happening with the BEPS policies and how Norway will implement this."
The 2016 Budget introduced a measure denying the application of the participation exemption for dividends received by a Norwegian company to the extent the company paying the dividends is entitled to a deduction for the payment made. The threshold for deductible interest expenses was reduced from 30% to 25% along with rules to neutralise hybrid mismatch arrangements in certain situations. The Ministry of Finance also announced that the CFC rules will be reviewed and changes will be submitted for public consultation.
The budget also included a reduced corporate tax rate effective from fiscal year 2016. The rate was reduced from 27% to 25%, affecting both corporate and individual taxpayers, and it is proposed that the corporate income tax will reduce to 23% by 2018.
"The Parliament also stated that further reductions should be considered depending on the international development of the tax rates, particularly in our neighbouring countries," said Joachim Bjerke, head of tax at BA-HR. "Thus, 23% may not be the final tax rate as the drive towards lower tax rates seem to continue, with the UK being one of the leaders."
Other amendments include the introduction of a new tax on financial services from 2017, an extension of the earnings stripping rules (with application of the rules to all interest payments) and the implementation of the proposed BEPS Action Points.
"Obviously the proposed amendments in the tax law are of key importance," said Per Daniel Nyberg, tax partner at KPMG. "Some proposed changes are going to be quite challenging to implement, taking into account non-discrimination rules in the EEA Agreement.
"The problem at the moment is we do not know too much about the details of the proposals. By way of example, it has been announced that the scope of the earnings stripping rules will be extended to third party loans, but that 'ordinary business related loans' will be shielded."
Taxpayers have continued to raise concerns about the amendments to the local tax system. "Everyone is happy seeing the corporate tax rate decline and that's all fair and nice. The maintenance of a net wealth tax and the increased tax rate on income from investment in companies has raised concerns, particularly as they apply to Norwegian resident private investors only," said Espen Nordbø, head of tax at Advokatfirmaet Haavind.
"Will increased owner taxation lead to emigration of high net wealth private investors, their business operations and jobs? There's some concerns about the interest deductibility rules and where they will be going," he added.
As a result of these changes to, and proposals for, domestic legislation, many find it difficult to adapt when the outcome of the international changes remain unknown. The tax authorities are becoming increasingly aggressive as they have allocated more resources and are building up competence within different areas. "I would say [the tax authorities are] more competent and more aggressive than before and that goes hand in hand with the BEPS initiative which of course also has a focus on aggressive tax planning," said Hveding.
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Rolf J. Saastad
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Ernst & Young AS
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Christin Erichsen Bøsterud
Tel: +47 977 78 314
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Advokatfirmaet PricewaterhouseCoopers AS
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Advokatfirmaet PwC is recognized as tax firm of the year in Norway for 2014, 2015 and 2016 by International Tax Review. PwC is the largest private tax firm in Norway and has had the largest growth among the Norwegian tax firms over the last five years.
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Selmer's tax team provide specialised services to Norwegian and foreign clients. Our services cover the spectre from advice and planning in connection with projects, transactions and reorganisations to tax due diligence and assistance with tax audits and tax complaints against Norwegian tax authorities.
The tax team includes 7 practitioners. We have particular expertise within the Real Estate sector, Private Equity (fund) sector, Renewable Energy and Financial Services sector. We also have a special emphasis on international tax and tax related to M&A and corporate reorganisations.
Selmer is the only Norwegian law firm with a team of certified auditors and economists and our assignments are often multi-disiplinary. With an intimate knowledge of the interplay between tax and accounting we are able to deliver advice with a unique approach lawyers traditionally do not have.
We also have a strong international focus. Selmer is the Norwegian member of Taxand Global Alliance – the world's largest global network of independent tax advisors, broadening our expertise and international approach and giving access to over 2000 tax advisers in nearly 50 countries.
|Corporate Income Tax||25%|
|Capital Gains Tax||25%||28.75%|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||0%|
|Branch Remittance Tax||0%|
A This tax applies to dividends paid to non-resident shareholders. Dividends paid to corporate shareholders that are tax residents and genuinely established in member states of the European Economic Area (EEA) (including the European Union [EU], Iceland and Liechtenstein) are exempt from withholding tax
Advokatfirmaet Haavind's tax team of eight professionals is headed by Espen Nordbø. It has experience in various tax matters including cross-border transactions, transfer pricing, tax controversy and international tax planning with particular strength in real estate, government, construction and materials, and energy industries.
Clients said the firm is reliable, delivers on time, provides good and accurate advice and "no tasks are too small for them". Clients also praised the firm's in-house professional expertise.
The team assisted on a tax neutral restructuring of Bergen airport, Trondheim airport, Stavanger airport and other commercial properties held by Avinor. The company holds an array of assets, real estate, commercial businesses, licensing rights and a variety of different obligations and is subject to particular governance by the government. The deal required complex valuations and allocations, managing public administration issues and getting approvals by high ranked government officials.
Anders Heieren leads the VAT and tax practice at Arntzen de Besche and has a wealth of experience in corporate and international tax as well as Norwegian tax. He has previously worked for the Norwegian Ministry of Finance and was a partner with a Big 4 firm. He manages the team which has expertise in assisting clients from the oil and gas, real estate, banking and finance, insurance and shipping industries. The team also assists several players in the aircraft industry regarding the leasing of aircrafts.
In the past year Marius Tyrland joined the firm from the Norwegian Ministry of Finance and Silje Andreassen from the directorate of customs and duties and the team now comprises six partners and five professionals.
Joachim Bjerke is head of the tax practice at BA-HR, supervising a team of 17 other professionals. The professionals assist clients in a range of tax services and are particularly strong in the extractives, shipping, private equity, and asset management and oil service industries.
Bjerke has extensive expertise in corporate tax and M&A and was in 2013 appointed by the government as a member of an eight-person expert committee to review the corporate tax system. The government published the recommendations in October 2015.
A client said: "My experience in dealings with BA-HR is excellent! The law firm has highly competent partners being hands-on [with] latest developments within the tax area. In addition to the partners – a community of highly skilled associates have been developed. All in all – this means that the service level and quality delivered is excellent and I regard them amongst the best in Norway."
Deloitte's tax department is headed by Tore Paulshus and offers in-depth assistance in a wide range of complex tax matters. The team works closely with clients to personalise solutions and has particular emphasis on BEPS compliance and tax risk management.
The team of 205 professionals, including 36 partners, is among one of the biggest practices in Norway. The professionals have experience in due diligence, planning, valuations and accounting as well as delivering global tax advice through a number of service lines including global employer services, corporate tax, international tax, transfer pricing and M&A.
The practice works across industries, specifically from the financial services, energy and resources, public sector, real estate and consumer business.
The firm is highly recommended by clients. One said: "Deloitte is a top class law firm and particularly in the tax and TP department."
DLA Piper's tax team comprises local and international tax specialists supporting clients in a wide range of services with focus on cross-border transactions, M&A, structuring and litigation. The team has a wealth of knowledge to assist clients from several industries, particularly in real estate, media, pharmaceuticals and life sciences, software and computer services, and energy.
Knut Olsen is the sole practitioner at Dr K Olsen Global Tax, assisting Norwegian and foreign clients with specialist knowledge in various areas with focus on shipping, airlines, telecommunications, cloth manufacturing and oil.
Olsen offers a range of tax services including global tax risk management, transfer pricing, shipping taxation, petroleum taxation, VAT, indirect tax and advanced global tax planning. With the ability to adjust its services depending on the international development and trends, the firm offers proactive and preventive services taking the global tax risks into account as well as the changing local tax environment.
Christin Bøsterud is the managing partner of the Nordic tax team at EY which assists clients in the full suite of tax and legal services including cross-border transactions, transfer pricing, direct and indirect tax, global compliance and reporting, and corporate tax. The Nordic tax team also supports clients in Sweden, Denmark, Finland and Iceland.
The firm's professionals are strong in managing tax issues in the real estate, private equity, oil, gas and energy, government and public sector, and diversified industrial products industries.
The tax team at Grette assists clients with several tax issues and has particular strength in VAT and customs and excise duties. Thomas Alnæs is the key contact at the firm and is experienced in corporate law, M&A, transactions and tax and VAT.
Harboe & Co is an independent law firm which specialises in tax advisory and has skills in corporate tax, indirect tax including VAT, direct tax and expertise in real estate and petroleum tax. Einar Harboe is the founder and head of the team and has more than 30 years of experience in tax advisory. He specialises in corporate and income tax, real estate, litigation and individual taxation.
Kluge offers a range of tax services with emphasis on VAT, tax litigation and experience in domestic and international taxation. Geir Even Asplin is a key contact for the tax practice and is an experienced tax adviser. His expertise is in corporate tax, M&A, due diligence, tax assessment and dispute resolution.
KPMG comprises a large tax department with 128 professionals including 21 partners and is headed by Per Ivar Skinstad. The full service provider has experience in M&A, tax planning, transfer pricing, business restructurings, VAT and indirect tax, administrative appeal processes and litigation.
Per Daniel Nyberg is another notable member of the team. He specialises in international corporate tax and transfer pricing. Anne Tengs-Pedersen and Gjertrud Behringer were also promoted to partner.
In one deal, the team took a leading role in the business restructuring of a listed company and its subsidiaries in Norway and abroad which resulted in the migration of the parent level company from Norway to Bermuda. This led to the de-listing of one entity and the listing of the Bermuda parent on the Oslo Stock Exchange.
Clients describe the firm as competent and social advisers and said they are happy to work and have meetings with the advisers.
PwC's tax team of 25 partners and 158 professionals specialises in international tax law, VAT, corporate law and transaction support. With offices in Oslo, Bergen, Stavanger, Kristiansand, Tromsø, Førde and Ålesund, the firm advises clients in all aspects of national and international tax and take on large assignments in all practice areas. Its professionals work in close cooperation with the national and global PwC network of accountants, consultants, investigation teams and financial advisers.
The tax team is headed by Trond Ingebrigtsen who has been working with VAT and other indirect taxes within PwC since 1997. He specialises in real estate VAT issues and frequently assists Norwegian and multinational clients on domestic and international tax matters.
In one deal, the team provided tax and VAT services for a cross-border demerger of a Swedish retail bank with a Norwegian branch in order to establish a stand-alone Norwegian bank, and subsequently offered advice regarding its listing on the Oslo stock exchange.
One client said: "I provide my highest endorsement to PwC Norway. They are simply the best- deeply technical, well connected to current developments, strategic in their thinking, clear in their communication and built around doing the right thing over the longer term. They are especially good with transfer pricing. Morten Beck is simply recognised as the best transfer pricing adviser in the country."
The tax professionals at Schjødt advice Norwegian and foreign multinationals from an array of industries including energy and offshore, pharmaceuticals, utilities, technology, property, trade and extractive industry investors. The firm offers a wide range of services including tax restructuring and planning, M&A, transfer pricing, VAT and other indirect taxes, tax disputes and litigation.
Sverre Hveding and Einar Bakko co-head the tax department at Selmer, Taxand Norway. The team comprises three partners and five professionals with financial and legal expertise and experience in tax audits, tax advisory, international tax planning, due diligence, dispute resolution and litigation.
The team has particular expertise within real estate, private equity, renewable energy, financial services, international tax and domestic and cross border M&A.
In one deal, the team assisted a foreign-owned Norwegian group in its financial and legal restructuring, which included changes in ownership and intragroup agreements and transfer pricing issues.
The firm is a member of the global Taxand network, broadening its expertise and international approach.
Tax professionals at Simonsen Vogt Wiig assist private and public-sector clients in connection with purchases, sales and restructuring. The team comprises specialists in various areas including petroleum taxation, VAT and international tax law. Additional services include valuation assignments and legal disputes in the courts.
Ulf Sørdal is the head of tax at Steenstrup Stordrange which comprises attorneys and economists working in all areas of commercial tax, property tax, VAT, customs and excise duties. The team has extensive knowledge in areas such as real estate and property, trade, services, industry and private equity. The practice is frequently involved in cross-border transactions, designing company structures, assisting Norwegian companies establish operations abroad and foreign companies establish operations in Norway, and preparing employee incentive programmes.
Sørdal is a corporate tax partner focusing on tax related matters and corporate transactions. He has a wealth of experience from Big 4 accounting firms and has experience in both individual and corporate tax.
The firm is a member of WTS Alliance, an international network of tax experts.
Thommessen's head of tax Ståle Kristiansen advises large Norwegian and international enterprises on domestic and international tax law, transfer pricing, corporate law and accounting law. He also advises clients in tax disputes and has experience litigating before the Norwegian courts.
The law firm offers a range of tax services including disputes, litigation, M&A, restructuring, due diligence and transfer pricing.
Wiersholm provides a range of tax services, with advisory strengths in corporate finance, banking, energy, construction and real estate. The professionals at the firm have experience in matters relating to domestic and international tax and assist both Norwegian and foreign multinationals operating in Norway on M&A, tax structuring, international tax planning, indirect and direct taxation.
Bettina Banoun, Andreas Bullen and Harald Willumsen are the key contact for the tax department.
Wikborg Rein has expertise in tax advisory and offers support in an array of tax aspects particularly corporate tax, M&A, transaction structuring for tax purposes and tax litigation. Anders Myklebust is a partner and part of the tax practice and focuses on tax law and company law. His practice covers all areas of tax, charges and duties with emphasis on corporate taxation.