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8 May 2017

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Norway Consulting on Interest Restriction Amendments

Norway's Ministry of Finance has published a consultation document on proposed amendments to the country's income expense deduction restrictions. Under current rules, the deduction of interest on related-party debt is limited to 25% of a taxpayer's EBITDA with an annual de minimis threshold of NOK 5 million for deduction without restriction. The proposed changes include:

  • Expanding the restriction to also apply for third-party loans;
  • Increasing the de minimis threshold to NOK 10 million; and
  • Introducing an optional group ratio exemption for taxpayers whose equity to current assets ratio is equal to or exceeds the ratio of the worldwide group as per consolidated financial statements (comparison may be made at the level of individual taxpayer or at the level of the Norwegian part of the group).

The Ministry intends to maintain the current EBITDA percentage (25%) and the 10-year carry forward of excess interest expense. Further the Ministry intends to maintain the exemptions for companies subject to special rules, such as financial institutions and petroleum companies.

Click the following link for the consultation document (Norwegian language). The changes are proposed to apply from the 2018 fiscal year.

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