Although the oil price slump hit the Norwegian economy hard, the country has seen growth in other areas, such as real estate and the services sector, which has buttressed the downturn of the oil industry. The prospects of the Norwegian economy are unlikely to be swayed as a consequence of BEPS measures, however, there is uncertainty around the changes.
Norway was one of the many countries to sign the multilateral instrument (MLI) in June 2017. The MLI lays the groundwork for the renegotiation of more than 3,000 double tax treaties and the implementation of minimal standards relating to treaty abuse and dispute resolution through a mutual agreement procedure. This reinforces Norway's commitment to the BEPS project.
Yet Norway was the only country to sign the MLI and not immediately disclose which articles it will implement. In a way this is just a procedural matter, where the Norwegian government will disclose the convention as it is presented to Parliament for a vote. Although Norway's general MLI positions were disclosed in July, the lack of concise information about what the Norwegian authorities have planned leaves taxpayers and their advisers to guess what the policies will look like.
"I think BEPS has started to have an impact on the market over the last year," said Hans-Martin Jørgensen, partner at Deloitte. "I don't think we saw that many projects related to BEPS coming our way, but that changed this year. It clearly has had an impact, particularly on the focus of multinationals, who have started reviewing their structures."
There is little sign of deviation from this course, partly because Norway already has many of the project's recommendations in place – a common pattern across the Nordic countries. The BEPS initiative has not come as a shock for the Norwegian market, something which is also true in neighbouring countries Sweden and Finland.
In line with global trends, there has been a steady increase in the amount of audits over the last 10 years, however the tax authorities' focus has somewhat changed. Questions over the substance of business operations are a part of the heightened focus on tax avoidance. This has generated demand for legal advice in compliance, but it also means more work for lawyers when it comes to disputes and litigation.
These trends look set to continue as the Norwegian authorities remain committed to the BEPS project. In some ways, Norway may be in the opposite position to other countries facing challenges from the BEPS measures. If the OECD and EU initiatives lead to greater harmony of tax policy across the board, countries like Norway stand to gain from a fall in tax competition.
However, there are good reasons to believe neither initiative will produce such harmony. Many countries disagree about the fine details of how to implement the BEPS measures, and these differences will produce different policies in the end. In other words, tax competition is very unlikely to end with BEPS.
Managing partner / Head of Tax & Legal Norway
Rolf J. Saastad
Partner / Attorney-at-law
Tel: + 47 90 74 75 56
Partner / Attorney-at-law
Tel.: +47 913 48 997
Hans Martin Jørgensen
Partner / Attorney-at-Law
Tel.: +47 99 44 60 61
Partner / Attorney-at-Law
Tel.: +47 913 48 997
Indirect Tax VAT
Customs and Global Trade
Partner / Attorney-at-Law
Tel.: +47 982 06 869
Global Employer Services
Stig A. Sperre
Tel.: +47 992 90 187
Tax Management Consulting
Per C. Evers
Tel.: +47 913 54 935
Private Company Services
Torill H. Aamelfot
Partner / Attorney-at-Law
Tel: + 47 95 92 68 07
Head of Legal
Corporate and M&A
Real Estate and Construction
Forensic / Insolvency
Partner / Attorney-at-law
Tel.: +47 481 26 326
Ernst & Young AS
Dronning Eufemias gate 6
Postboks 1156 Sentrum
Tel: +47 2400 2400
Regional Tax Leader
Christin Erichsen Bøsterud
Tel: +47 977 78 314
Country Tax Leader
Øystein Arff Gulseth
Tel: +47 982 06 387
Business Tax Services
Tel: +47 982 06 168
Per Oskar Tobiassen
Tel: +47 982 06 269
International Tax Services
Tel: +47 958 71 786
Tel: +47 917 86 479
Mette A. Granheim
Tel: +47 416 50 572
Tel: +47 977 56 861
Global Compliance and Reporting
Tel: +47 982 06 684
People Advisory Services
Johan A. Killengreen
Tel: +47 982 06 375
KPMG Law Advokatfirma AS
P.O. Box 7000 Majorstuen
KPMG Law Advokatfirma AS acts as a full-service law firm for national and international corporate clients. KPMG Law Advokatfirma is a fast growing law firm with offices in seven Norwegian cities. Through multidisciplinary cooperation, the firm is able to combine its broad tax and legal expertise with the outstanding business expertise of the overall KPMG network.
Areas of Expertise & Contacts:
Tel.: +47 4063 9265
Global Mobility Service:
Tel.: +47 4063 9055
Global Transfer Pricing Services:
Tel.: +47 4063 9022
Tel.: +47 4063 9188
Deals Advisory, Mergers & Acquisitions Tax:
Tel.: +47 4063 9183
Global Indirect Tax Services
Tel.: +47 4063 9157
Global Legal Services:
Tel.: +47 4063 9050
Global Compliance Management Services:
Tel.: +47 4063 9334
Tel.: +47 4063 9190
Energy & Natural Resources Tax:
Tel.: +47 4063 9395
Financial Services Tax:
Tel.: +47 4764 0770
Dispute Resolution & Controversy Services:
Tel.: +47 4063 9188
Value Chain Management:
Tel.: +47 4063 9265
Global R&D Incentives
Tel.: +47 4063 9188
Sovereign Wealth & Pension Funds:
Tel.: +47 4063 9183
Advokatfirmaet PricewaterhouseCoopers AS
Dronning Eufemias gate 8
N-0191 Oslo, Norway
Tel: +47 0231 6
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.
No matter if you're a multinational corporation, a SME or a private individual: if you want to optimize your fiscal and legal position, PwC Norway is the right choice.
As a global network of local leaders, PwC offer you a 360-degree range of tax services. Our tailor-made solutions drawing from our knowledge and experience from numerous countries and industries will boost your business. Turn our leadership into yours: our 211 experts and 8 offices across Norway are ready to assist you.
National corporate tax:
M&A / Transaction Services:
Real Estate / Transaction Services
Lars Helge Aasen
VAT / Customs & Excise:
Global Compliance Services / Company Administration Services:
Human Resource Services:
Shipping / Offshore / Oil Services:
Financial Services / Sovereign Issues:
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.
Advokatfirmaet Steenstrup Stordrange DA
Cort Adelers gate 33
Ulf H. Sørdal
Phone: + 47 4191 6717
Main areas of focus:
Corporate Tax, Mergers & Acquisitions, Transfer Pricing, International Tax & Permanent Establishments, Indirect Tax, Customs, Private Clients, Global Mobility, Tax Controversy, Tax Technology
|Corporate Income Tax||25%|
|Capital Gains Tax||24%|
|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
Espen Nordbø is the head of tax at Advokatfirmaet Haavind. He is a tax law specialist with impressive expertise in property development, aviation and transactions. A key figure at the firm is founding partner Arne Haavind, who specialises in tax litigation and has represented cases before the Norwegian Supreme Court for almost 30 years.
Advokatfirmaet Haavind offers the entire scope of tax and duties services, with key strengths in cross-border issues, trade and transactions. The firm often liaises with the Norwegian tax authorities. The Haavind M&A team recently advised Anthon B. Nilsen Skoledrift on the sales of university college Westerdals Oslo ACT to Høyskolen Kristiania.
Anders Heieren heads the tax and transfer pricing teams at Arntzen de Besche. He is widely recognised for his expertise in private-equity deals and the energy industry. The firm offers its clients assistance in a comprehensive range of tax areas, such as structuring, transfer pricing, strategic planning, tax disputes and cross-border transactions.
With key offices in Oslo, Stavanger and Trondheim, Arntzen de Besche advises Norwegian and foreign multinational clients on M&A restructuring, dispute resolution and VAT. The firm has a strong set of industry focus areas, such as oil and gas, shipping, real estate, fast food, pharmaceuticals and financial services.
Three of the team's lawyers, Ulf Werner Andersen, Cecile Dyrnes and Kåre Moljord, are admitted to the Supreme Court of Norway. The practice works closely with law and accounting firms all over the world.
Partner Joachim Bjerke is the head of tax services at BA-HR. He also oversees the firm's TP unit. Bjerke is a member of the Norwegian government's committee on corporate tax and has a wealth of knowledge in corporate tax, transfer pricing, cross-border transactions and tax disputes.
There are four other distinguished partners at the firm, Jan Jansen, Helge Olav Bugge, Anne Sofie Bjørkholt and Frode Talmo, as well as 10 other fee earners. The tax practice is held in high regard by clients and peers alike. BA-HR offers an extensive range of tax services to key industry sectors like energy, finance, shipping and insurance. The firm's remit extends to tax disputes and litigation. The firm is advising a number of important oil companies on the Norwegian Oil Taxation Office's position. It is also advising several companies on the restructuring from transparent companies to limited liability companies due to changes in the interest limitation rules.
The tax practice at BDO Norway offers an extensive range of services, such as international tax planning, transfer pricing, transactions, business tax, VAT and customs duties. Two key contacts at the firm are Bjørn Kleiven and Ståle Lorås. Key practice areas include cross-border restructuring, tax disputes, M&A deals, joint ventures, employment tax, tax treaties and EU tax law and regulations. The team has offices in Oslo, Trondheim, Tromsø and Stavanger.
Clients include financial institutions, energy companies, tech start-ups, non-profits and public sector bodies. The firm's client base is drawn from key sectors like oil and gas, resource extraction, manufacturing, fishing and shipping.
Antonio Holstad is the head of the tax department at Brækhus, particularly overseeing direct tax services. He works closely with fellow partner Nils Eriksen, who has more than 25 years of experience and heads the indirect tax group. The practice consists of four partners and 10 other professionals.
Brækhus offers clients a wide range of tax services, including specialist VAT advice and international and corporate tax law. Another important team member is John Spissøy, who oversees corporate tax services. He previously worked for Deloitte Norway in charge of tax services to the oil and gas industry. Spissøy specialises in the energy industry, where he has served major multinational clients.
Brækhus has strong expertise in EU and EEA tax law, especially with regard to tax disputes and litigation, including cases at the EFTA court. The firm's client base includes major trading platforms for Nordic oil and gas.
Deloitte's Norwegian tax practice is overseen by Rolf Saastad. The accounting firm provides the complete range of tax services, such as corporate reorganisation and transactions, with 36 partners and more than 170 other tax professionals.
Another important partner is Hans-Martin Jørgensen, who leads the firm's TP unit. The tax practice continues to expand, recently hiring Karin Remøe, Jonas Odland and Olav Nærdal. As the firm is a part of Deloitte Nordic, the full service range is integrated with those of Denmark, Finland, Sweden and Iceland.
Deloitte Norway has a strong client base, including domestic and international companies. Many companies on the Oslo Stock Exchange (OBX) are clients of Deloitte Norway. This includes key industry sectors like oil and gas, shipping, and infrastructure.
As part of Deloitte's 2020 strategy, the Norwegian firm has deployed new tax technology to streamline service delivery. For instance, Deloitte offers clients automated means for compliance and value chain analysis. Tax technology is a key part of Deloitte Norway's offering to clients.
Preben Aas is the head of tax at DLA Piper in Norway, working closely with Siv Øveraasen. Aas and Øveraasen have a wealth of experience in tax and have liaised with Norwegian politicians on tax law. The tax group's key focus areas include corporate tax, real estate and the public sector, as well as investment, auditing and dispute resolution.
DLA Piper advises major domestic and multinational companies on the tax implications of investment, whether it is in Europe or Asia. The team has continued to expand in 2017, taking on Jonas Aartun as an associate partner. Aartum previously worked for Aker Solutions. He has experience with Norwegian and international tax law and mainly assists clients with M&A deals, reorganisations and incentive schemes. Aartum specialises in the energy and shipping industries.
Knut Olsen is the sole practitioner at Dr K Olsen Global Tax. With 36 years of tax experience, Olsen is a tax and transfer pricing specialist with expertise in risk analysis. He is also an anti-corruption consultant.
Based in Oslo, Olsen's services include tax court testimony and expert reports, and tax risk management, as well as tax planning, M&A transactions and business restructuring to lawfully minimise an organisation's tax burden. Some noteworthy clients of the firm include Ryanair, BP, Norway Business School, Thomas Jefferson University, Shanghai University and PwC.
Christin Bøsterud is the managing tax partner at EY. With 25 years of experience, Bøsterud oversees the full range of services, such as direct and indirect tax, compliance, transfer pricing, risk management and transactions.
The tax practice often advises and assists multinationals across a variety of industries, including sectors such as pharmaceuticals, technology, energy, telecommunications and shipping. As part of the Nordic tax team, the Norwegian practice collaborates with the firms in Sweden, Denmark, Finland and Iceland.
Grette features a tax team that supports clients with general advisory services as well advice on transactions, crisis management and dispute resolution. A key contact in the tax department at Grette is partner Thomas Alnæs. The firm has been chosen to lead an OECD working group developing international guidelines for legal practice, the only legal or advisory firm to receive this honour. In addition, Grette's tax practice is especially strong assisting clients with cross-border issues.
Specialising in direct and indirect tax law, Harboe & Co has a team of eight lawyers based in Oslo. The firm has been widely regarded as a top practice in the field of tax law, with additional expertise in value added, real estate, and petroleum tax.
The firm prides itself on being a smaller, specialist firm employing lawyers with particular expertise. These include its founder Einar Harboe, a lawyer admitted to the Supreme Court, who has authored many books and articles on the subject of tax law, Ivar Hobbelhagen, with extensive experience in corporate and foreign taxation, Harald Hauge, Christian Grevstad, Egil Stefan Eilertsen, and Jarle Schelander, all of whom are partners at the firm.
Originally founded in 1923 and now with offices in Oslo, Stavanger, Bergen and Hamar, Kluge works in all major fields of business law. Key tax specialist at the firm include partners Eirik Jensen, Frode Olsen, and Geir Even Asplin. The tax practice works with a range of domestic and international business, and also provides a specialised, dedicated service for start-ups. The tax team provides tax litigation and tax advice, with a special focus on companies, high-net-worth individuals and energy tax, and represents cases at the Supreme Court of Norway.
The tax department at KPMG is overseen by managing director Per Ivar Skinstad and chairman of the board Thor Leegaard. With 22 partners and 116 other professionals, KPMG Norway offers the complete spectrum of tax advice.
KPMG Norway maintains positive relations with the tax authorities and often advises on legislative issues and regulatory reform. Other key team members include energy specialist Jan Samuelsen, and Per Daniel Nyberg and Svein Andresen, who both oversee TP services. The tax department continues to expand, with Jørn Sandnes and Fredrik Klebo-Espe recently joining the firm from Schjødt and the UK branch of KPMG.
The practice has expertise in cross-border structuring, tax planning, transfer pricing, litigation, M&A and other transactions. The firm has a varied client base ranging from the energy industry, aquaculture and pharmaceuticals to consumer goods, IT and financial services.
The tax practice at PwC Norway is overseen by Trond Ingebrigtsen. He has more than 20 years of experience, with particular strengths in domestic and international VAT matters. His key practice areas include real estate, logistics and distribution across borders. This complements the firm's expertise in corporate and international tax law and transactions.
PwC Norway comes highly recommended by peers and clients alike, with offices in Oslo, Bergen, Stavanger and Trondheim, among others. The tax team offers the complete spectrum of tax services, including risk management, compliance, M&A transactions, restructuring and transfer pricing. The firm advises clients from key industry sectors like energy, private equity, finance and retail.
Schjødt is a large, highly-regarded firm, and has advised on more M&A transactions than any other firm in Norway for the past seven years. The firm's tax department works with domestic and international organisations with a focus on strategic tax planning, transaction structure, cross-border issues and changes to corporate structure.
Schjødt has worked with a wide range of industries including offshore, pharmaceuticals, technology and property. It also provides specialised energy tax services and the tax team works closely with the firm's real estate, M&A and litigation departments. Key contacts within the tax department are partners Cecilie Amdahl and Morten Sandli. The firm has offices in Oslo, Stavanger, Bergen and Ålesund.
Einar Bakko and Sverre Hveding lead the tax and duties group at Advokatfirmaet Selmer DA, Taxand Norway. The firm offers advice to Norwegian and international clients on a spectrum of tax matters, such as planning, due diligence, auditing and complaints against the tax authorities.
Founded in 1988 with offices in Oslo and Trondheim, Selmer is the Norwegian branch of the international tax network Taxand. The firm's team has extensive experience working with public and private sector companies in Norway.
Selmer's team has strong expertise in stock incentive schemes, cross-border issues, M&A transactions and corporate reorganisations. The firm has worked in fields such as real estate, shipping, oil and gas, renewable energy and private equity.
With a team of 11 lawyers spread across offices in Oslo, Kristiansand, Bergen, Trondheim, Tromsø and Stavanger, Simonsen Vogt Wiig works with public and private sector clients in fields such as restructuring, transactions and succession planning.
The firm also includes tax specialists in the fields of oil and gas, VAT and international tax. Key contacts in the tax department are partners Eldar Nesset, Egil Horstad, and Vidar Kleppe. The team also works closely with Simonsen Vogt Wiig's other departments to provide a fully integrated service line.
Finn Backer-Grøndahl heads the tax and duties department at Thommessen, where the firm offers the complete service line. The firm's remit includes structuring transactions, dispute resolution, transfer pricing and litigation. The practice consists of 18 professionals, including six partners, comprising legal and tax specialists, with a strong focus in corporate restructuring and transactions.
Thommessen offers clients support with M&A deals, restructuring, tax audits, mutual agreement procedures and advance pricing agreements. Key team members include Hanne Skaarberg Holen and Ståle Kristiansen. The tax practice continues to grow, recently hiring associate Thale Kristine Fannemel Espeli.
The tax group has a track record of taking on large-scale and complex cases. The firm's client base includes domestic and foreign multinational companies, spanning key industry sectors like oil and gas, healthcare, finance and shipping.
The tax group at Wiersholm offers a comprehensive range of tax services, including structuring, disputes and litigation. Key contacts at the practice include Bettina Banoun, Andreas Bullen and Harald Willumsen. The firm offers advice to Norwegian and foreign multinational companies on M&A deals and tax planning.
Banoun is especially strong in litigation and she has represented clients before the European Free Trade Area (EFTA) Court, whereas Bullen is highly respected for his expertise in corporate structuring and transfer pricing. Willumsen focuses on M&A deals and litigation, particularly for private equity investors.
The team has a strong skillset in key industry sectors, such as financial services, energy and real estate. The firm's focus on financial services covers areas like private equity, asset management, capital markets and insurance.
Wikborg Rein is an acclaimed Norwegian law firm with a tax group specialising in business tax, corporate tax and litigation. The firm works with clients in the fields of shipping, offshore and energy, and natural resource industries. With offices in Oslo and Bergen, Wikborg Rein is made up of three partners and eight associates.
These partners include Anders Myklebust, an expert on tax law and company law who has published a book on the subject, and Are Zachariassen, whose experience is in tax law, company law, stock exchange and securities legislation. Another key partner is Kaare Andreas Shetelig, who is head of the firm's litigation and arbitration practice with extensive experience in dispute resolution, professional liability, company law, energy law, contract law, pension law, and public administration law.