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24 September 2021

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Norway to Relax Tax Continuity Conditions for Tax-Free Cross-Border Reorganizations

Norway's Ministry of Finance has launched a public consultation on a proposal for changes in the rules on tax-free cross-border mergers, demergers, and share exchanges, in order to simplify the rules and facilitate better organization of business activities. The rules on tax-free cross-border reorganizations would be amended in relation to the condition the transaction is carried out with tax continuity, which is meant to safeguard the Norwegian tax base by ensuring that the tax exemption on the transaction does not become final, but that taxation is instead postponed to a later tax-triggering event.

The tax continuity condition currently applies at the company and/or shareholder level in Norway and at the company and/or shareholder level in the relevant foreign company's jurisdiction. According to the Ministry, the latter condition for tax-continuity in foreign jurisdictions has been resource-intensive for taxpayers and the tax administration. The condition has also proven difficult to fulfill in certain cases, resulting in the taxation in Norway of transactions intended to be facilitated by the rules. To resolve the issues, it is proposed to amend the rules by removing the condition for tax continuity abroad.

The deadline for comments is 22 December 2021.

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