Corporate Tax 2023 Comparisons

Businesses generally adopt a corporate form, usually as a limited company (Aksjeselskap or AS). A limited company may have only one shareholder, and this shareholder may also be the only employee in the company. The minimum share capital is currently NOK30,000 (approximately EUR3,000). Listed businesses must be organised in the form of a public limited company (Allmennaksjeselskap or ASA), which requires multiple shareholders. Both the AS and the ASA are taxed as separate legal entities. Company law allows different groups of shares with different rights regarding, for example, voting power and dividends. All shares have to be issued and the identity of all the shareholders must be recorded by the company.

General partnerships are also used, and require two or more partners. General partnerships are often combined with a limited company, usually with limited companies being the partners. They are also seen in businesses otherwise organised through a personal business, when two or more persons combine resources and interact in conducting a business. A business co-operation involving shared upside and downside may be deemed a partnership for tax purposes, regardless of any formal partnership agreement. Limited partnerships may be used in some cases, but are less common after changes were made in the tax rules. Partnerships are transparent for tax purposes.

Personal business may also be conducted without a corporate form. Personal businesses outweigh the other forms of business in sheer numbers, but the personal business is usually used when there are very few or no employees besides the owner. Some business activities may only take the form of a personal business, including that of farming. A person may transfer their personal business to a fully owned limited company without immediate taxation.

There are also other varieties, but the limited company is most common. Norwegian law does not recognise trusts with the settlor or the settlor’s relatives as beneficiaries. If a trust is used for business purposes (eg, as the top unit owning a group of companies), the settlors will have to abandon their economic interest. A trust is taxed as a separate entity. There are a few such trusts in Norway, controlling fairly sizeable businesses.

The most common transparent entities are general partnerships. They may be used in all types of businesses, but are often used in shipping, and also in service businesses where the personal partners play a significant role, such as law firms. Being transparent entities, partnerships allow for an immediate use of taxable individual deductions by the partners. Therefore, they are more flexible than limited companies when it comes to the distribution of proceeds and tax consolidation with other business activities of the partners.

Limited liability partnerships were popular until a few years ago, when the tax rules were tightened. A limited partner may now only carry forward any tax loss against future income from the partnership, and not use it as a deduction against other taxable income. This has made limited liability partnerships less attractive for investment groups. Any proceeds from such investments will normally be exempt from taxation for partners other than individuals, thus not resulting in any future taxable income.

The determination of the residency of a company or partnership will depend on its country of registration, or on whether its effective management is in Norway. A company registered in Norway will be resident there. A company resident in another country according to a double tax agreement will not be considered resident in Norway according to internal rules either.

The corporate tax rate is 22%. There are reduced rates for shipping, which is taxed under a tonnage tax regime, and increased rates for some financial services (25%, in addition to increased payroll tax), for:

• upstream activities on the Norwegian continental shelf (78%);
• the production of hydroelectric power (67%);
• wind-generated power (62%); and
• sea-farming for salmon and trout (62%).

Dividends from limited companies and distributions from partnerships to an individual are multiplied by a factor of 1.72, and then taxed, resulting in an effective tax rate of 37.84%. This gives a taxation of 51.5% for the company and owner in total.

Salaries are taxed at a progressive rate, reaching 47.4% from approximately NOK1.5 million. Income from a personal business is also taxed at a progressive rate, reaching 50.6% from approximately NOK1.5 million.

Income from a personal business is subject to a slightly higher contribution to the national social security scheme than employees’ salaries, thus topping out at a higher rate than salaries and distributions/dividends. However, salaries are subject to a payroll tax of 14.1% (19.1% for some financial services and for salaries above NOK750,000), which is reduced in the rural and northern parts of Norway. In the most northern parts, the payroll tax is 0%.

Taxable profits are calculated according to the General Tax Act on an accrual basis, not according to accounting profits. The most notable differences are the taxation of capital gains from equity investments, which are tax-exempt for corporate shareholders, and depreciations of assets, which are calculated according to special tax rules. The values of assets for tax purposes are usually based on initial cost (minus accumulated tax depreciation, if applicable), not market value. Unrealised exchange gains on long-term debt and receivables may be deferred, while unrealised exchange losses may be deducted as incurred. Regarding timing issues, the taxation of financial instruments may also differ between accounting and tax purposes.

There are limited incentives for technology investments, but there is a possibility to claim a tax refund – the so-called Skatte-Funn (Tax Discovery) – for costs related to development projects approved by the Norwegian Research Council. This is intended to be a direct economic incentive, but is capped at NOK25 million. There is also a wider opportunity to deduct costs related to R&D directly, rather than capitalising such costs.

There are not many special incentives applicable to particular industries:

• shipping has a tonnage tax regime (see 1.4 Tax Rates); and
• payroll costs are reduced in the rural and northern parts of Norway.

There is also a separate deduction for investments into new entrepreneur businesses, but this is capped at NOK1 million. Certain temporary incentives were introduced during the COVID-19 pandemic, with the most notable being direct deduction and uplift against the Special Tax basis (56%) on investments in upstream activities within the frame of the Norwegian Petroleum Tax Act. These incentives are no longer available for new projects.

Losses may be carried forward indefinitely, and may be offset against business income, capital gains or other income. There are some limitations when it comes to losses and income from inside/outside the Special Tax regimes, like the tonnage tax regime and the resource rent regimes on petroleum income and income from hydroelectric and wind-generated power production and sea farming. If a business ceases activity, it is possible to carry back losses against the two previous years’ income. A relief of debt (debt forgiveness) will normally reduce a carry forward loss equally, but a conversion of debt into equity (share capital) is not regarded as a relief of debt.

All interest may be deducted, even if not paid as part of an income-generating activity. However, there are limitations on the deductibility of interest, which are applicable to all companies except those subject to Special Tax in the Petroleum Tax regime. The present rules include limitations on interest deduction on both external debt and debt to related parties. Interest costs exceeding 25% of EBITDA are not deductible, but there is a threshold of NOK25 million on net interest for the Norwegian part of the group before the rules apply. The EBITDA is calculated on the taxable result.

There is an escape clause if the Norwegian entities (or the Norwegian part of the group) have a debt/equity ratio similar to the group as a whole. The escape clause enables fully Norwegian groups to deduct the full interest on external debt, while groups with companies outside Norway may not always deduct full interest costs.

There is also a restriction on interest on debt to related parties, where the debtor is not part of the group. The threshold is then reduced to NOK5 million.

Neither of the restrictions apply to companies that are subject to Special Tax for petroleum activity (exploration, exploitation and pipeline transportation on the Norwegian continental shelf).

Disallowed interest costs may be carried forward and deducted within the 25% of the EBITDA in the following ten years.

Within each legal entity of a group, losses and profits/gains are generally tax-consolidated, except for limitations regarding consolidation between the ordinary tax regimes and the Special Tax regimes (see 2.4 Basic Rules on Loss Relief).

There is a wide opportunity to consolidate taxable results between companies within the Norwegian part of a group, conditioned upon more than 90% common ownership/control. Consolidation is performed through group contributions, which may be given in any direction and to any Norwegian company within the group. The group contribution is deductible for the contributing company, and taxable for the receiving company. It may also be applied for (to or from) permanent establishments that are taxable to Norway. In some cases, group contributions may also be contributed without a tax consequence, making it possible to refinance companies without using debt or equity from the top company. Based on strict conditions, cross-border group contributions may be allowed if the receiving company is resident within the EU/EEA and risks losing a carry forward loss. Group contributions may not be applied for income that is subject to Special Petroleum Tax or ground rent taxation (hydropower, windpower and sea farming).

There is a wide exemption when it comes to company and partnership taxes on capital gains from equity investments. The participation exemption applies to all investments, in both listed and unlisted companies, and also for minority ownership shares. If the ownership share is less than 90%, 3% of received dividends are taxed at a rate of 22%. The participation exemption does not apply to investments in companies that are resident in low-tax jurisdictions outside the EU/EEA, and it only applies to holdings above 10% that are held for more than two years, if resident in normal tax jurisdictions outside the EU/EEA. There are a few conditions, and investments in company structures that are not familiar to or recognised by Norwegian company law have proved especially challenging. However, investments in other limited companies, also abroad, are almost without exception taxed according to the above-stated general rules.

There are no stamp duty or other taxes payable on an equity transaction, but there is stamp duty (2.5%) on real estate transactions. However, most business-to-business real estate transactions are executed as a sale of shares in a company owning the real estate, thus not triggering any stamp duty.

Most local communities in Norway impose real estate taxes, of up to 0.7% of the market value of the real estate. The VAT rate is 25% but does not apply on transfers of real estate and enterprises. There are no other notable taxes, but there are various customs taxes. Norway also tends to tax commodities that are deemed not healthy or harmful to the environment, such as alcohol, tobacco, sugar, petrol, cars and emissions.

Most closely held local businesses (fewer than four employees) operate as personal businesses, in non-corporate form, at least when it comes to sheer numbers. Included in this category is a number of farmers and businesses that do not constitute a full-time occupation. However, the government has eased the requirements contained within company law, in order to make the limited company more attractive for closely held businesses.

The tax rates are set out so that there should not be much tax incentive to transform earnings into corporate income (see also 1.4 Tax Rates). To a large extent, the capital gains taxation of individuals has been increased, giving a combined total tax payable by the company and the individual owner that is quite close to the tax rates on salary. There is some case law concerning whether the company (corporate income) or the owner (salary) is the correct recipient of the payment, but this issue will usually be avoided by entering into agreements that make it clear that the services provided are rendered from the company to the third-party buyer, and do not constitute an employer-employee relationship between the owner and the third-party buyer.

The participation exemption rules were made with the intention of accumulating earnings for reinvestment purposes. The tax authorities have stated that they will not challenge whether a distribution of dividends should (partly) be reclassified as salary, nor any non-distribution, even though the owner performs activities for the company that would otherwise call for remuneration.

The ordinary capital gains taxation applies, bringing the effective tax rate up to 37.84% (see 1.4 Tax Rates).

There are no differences between the taxation of capital gains from closely held corporations or publicly traded corporations (see 3.4 Sales of Shares by Individuals in Closely Held Corporations and 1.4 Tax Rates).

Norway is not part of the EU, but is a part of the EEA Agreement with the EU. Within the EU/EEA, discrimination on grounds of nationality and restrictions on the freedom of establishment are generally not permitted. A company resident in another EU/EEA country will therefore be treated as a Norwegian company, including not being taxed on capital gains from companies resident in Norway.

For individuals and companies outside the EU/EEA, Norway imposes a 25% withholding tax on dividends. A lower rate may follow from a relevant tax treaty.

A withholding tax on interest and royalties and on rent on certain material assets, like ships, vessels, helicopters and planes, was introduced in 2021. The withholding tax applies to payments to related parties that are resident in a low-tax jurisdiction. “Low tax” is less than two thirds of Norway’s tax rate, which would be about 14.7% under Norway’s current tax rate of 22%. The withholding tax will not apply if the receiving related party is established within the EU/EEA, unless the establishment is deemed wholly artificial. Dividends from companies that are subject to Special Tax on petroleum activity in Norway are exempt from withholding tax, subject to certain conditions being met.

A special point of interest for the Norwegian tax authorities is whether the recipient of the outgoing dividends, interest or royalties is genuinely (not wholly artificially) established within the EU/EEA. 

In order to obtain double protection from both the EEA Agreement and the applicable double tax agreement, many investors use companies that are resident in the EEA for investments in local corporate stock. Norway, however, does not recognise wholly artificial holding companies and generally applies a strict “substance over form” approach.

There is quite a lot of attention in Norway regarding the use and misuse of tax treaties, although there have not been many cases. Norwegian authorities are anxious to see results from the BEPS initiative, including the limitation of benefits (LOB) and principle purpose test (PPT) introduced to many treaties as a result of BEPS. Norway has ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI), which entered into force for Norway on 1 November 2019. The MLI became effective for withholding taxes from 2020 and for other treaty regulations (eg, permanent establishments) from 2021.

The biggest transfer pricing issues for inbound investors have concerned the use of debt, and whether the interest rate and the debt-to-equity ratios are at arm’s length. This has not been as important in the last few years for companies not subject to the Petroleum Tax regime, after the introduction of a limitation on the deductibility of interest paid to related parties (see 2.5 Imposed Limits on Deduction of Interest). Transfer pricing issues seem to have taken a turn, and more cases now involve payment for the use and ownership of intangibles, and also the re-evaluation of transactions, including business restructurings.

The Norwegian tax authorities accept the use of related party limited risk distribution arrangements for the sale of goods or the provision of services, but look closely into the actual risks being taken, and the actual remuneration.

The Norwegian arm’s-length principle has a direct reference to the OECD standards and, as such, should follow the OECD standards. However, taxpayers and the tax authorities do not always agree on how the OECD standards should be understood, and some may think that the Norwegian authorities are somewhat aggressive in their approach.

The Norwegian tax authorities use and accept the use of mutual agreement procedures and double tax treaties. The tax authorities have a dedicated workforce that deals with such cases, and have issued guidelines on when and how such procedures are conducted. To some extent, the tax authorities also allow for advance pricing agreements, when possible, according to the double tax agreements. However, reaching a unified conclusion may be difficult, and very few tax treaties to which Norway is a party contain arbitration provisions.

Local authorities do not have the ability to give one-sided advance pricing rulings if they are outside the mutual agreements under the double tax agreements. There have been some discussions on the long duration of the mutual agreement processes, but such discussions do not seem to be exclusive to Norway.

Compensating adjustments are normally allowed when a transfer pricing claim is settled. There are special provisions in the tax administration act to make sure that the tax authorities make compensating adjustments. If a unified conclusion can be reached in a mutual agreement procedure (MAP), the conclusion is usually followed.

Local branches of non-local corporations are not taxed any differently to local subsidiaries of Norwegian groups. A local branch is taxed according to the same rules as local limited companies, including the participation exemption regarding equity investments. If the branch belongs to a company that is resident within the EU/EEA, the EEA Agreement provides a legal framework protecting against any discrimination towards a branch compared to a local subsidiary. Most tax treaties to which Norway is a party include non-discrimination clauses that provide a similar type of protection.

Capital gains of non-residents are not taxed. A non-resident might, however, own the stock through a Norwegian branch. The sale of stock in other Norwegian corporations will then potentially be taxable, but the participation exemption will make any capital gains from the sale of stocks in Norwegian companies exempt from Norwegian tax in most cases.

There are no change of control provisions that could trigger tax directly. However, a change of control higher up in the group could indirectly affect the Norwegian entity through a change in which other companies are regarded as related parties. In addition, a change of ownership in a Norwegian company may affect the applicability of withholding tax (see 4.1 Withholding Taxes).

Formulas are not used as a method of determining income as such, but income accrued by a foreign-owned local affiliate will typically be compared against other companies in similar businesses/markets in order to seek indications of the improper use of transfer pricing.

The local affiliate needs to justify the payment for a service or goods having been provided for the benefit of the local affiliate, and that the price for such service or goods is at arm’s length.

There are rules limiting the deductibility of interest paid to a related party. The limitation applies to both internal payments and cross-border payments (see 2.5 Imposed Limits on Deduction of Interest). For companies that are subject to Special Petroleum Tax, the maximum interest deduction in the Special Tax base is capped as a calculated portion of the written down tax value of the company’s facilities at the end of the year compared to the company’s average interest-bearing debt during the income year. However, this limitation is general and does not only apply to loans from related parties. Interest deductions are not allowed at all in the resource rent tax regimes – that is, hydroelectric power (57.7%), wind generated power (51.3%) and sea-farming (51.3%).

A withholding tax on interest paid to related parties was introduced in 2021 (see 4.1 Withholding Taxes).

Norway imposes a full, global tax liability on resident companies on all income earned inside and outside of Norway. Foreign income is only exempt when a treaty calls for an exemption, with a few exceptions. Income from foreign petroleum exploration and production is tax-exempt.

If foreign income is exempt due to either a treaty or the few internal exceptions, neither local nor global-related expenses related to such income are deductible.

Dividends from foreign subsidiaries are taxed under the participation exemption scheme. The participation exemption will normally apply to any subsidiary, except subsidiaries in low-tax countries. If capital gains are not exempted, they are taxed at 22%. There are also rules allowing for the underlying tax paid by the subsidiary to be offset against Norwegian taxation of the dividends. With the broad participation exemption, such offset is less practical than before the participation exemption was introduced (in 2004).

A subsidiary in a low-tax jurisdiction might be subject to Norwegian CFC taxation. Dividends from a CFC-taxed subsidiary qualify under the participation exemption.

The transfer or use of intangibles developed by a Norwegian entity is taxed based on an arm’s-length remuneration.

Norway has quite strict CFC rules. Income earned by a subsidiary is subject to taxation as though the subsidiary were Norwegian, conditioned upon the subsidiary being controlled or owned more than 50% by Norwegian entities. The entities do not need to be part of the same group.

All income from a non-local branch is taxed according to Norwegian rules. Norway taxes resident companies on their worldwide income, including all income from foreign branches, subject to limitations in any relevant tax treaties.

Elements of the “substance over form doctrine” applied by Norway as a general anti-avoidance rule, which was previously based on case law, is now formalised in Section 13-2 of the General Tax Act. The tax treatment of foreign companies using a corporate form that differs from the forms recognised in Norwegian company law tends to create practical problems.

The sale of shares in non-local affiliates is usually covered by the participation exemption (see 6.3 Taxation on Dividends from Foreign Subsidiaries).

Anti-avoidance provisions include a statutory general anti-avoidance rule, a general provision in the General Tax Act aimed at reduced income due to community of interest between parties/companies involved in a transaction, and more specific anti-avoidance rules, including CFC regulations, a provision for limiting use of loss carried forward and other tax positions after reorganisations, business transactions and regulations limiting the deductibility of interest.

The Norwegian tax period is usually January 1st to December 31st. A tax return is due before May 31st in the year following the taxable period. A statement of taxable income is presented to the company mid-October in the year after the year of income. Taxes are due in three instalments during the year following the year of income, with the last instalment, later than October, settling the balance.

Controls and audits may be conducted during the income year and before the tax return is submitted, but audits are usually performed after October in the year following the income year. The company may change its taxable income within three years after the end of the year of income, and the Norwegian tax authorities may reassess the taxable income if the taxpayer has been notified of such reassessment within five years following the year of income. In the event of deliberate tax fraud, the tax authorities may reassess within ten years.

Norway is a high-tax jurisdiction by tradition, in which inbound investments have made up a large part of the private economy. Furthermore, the general legal system is largely based on a doctrine of “substance over form” compared to many (most) other comparable legal systems. This is also the case with respect to Norwegian tax law. The concept of taxation based on economic substance and reality rather than formalities has been recognised for a long time. There is even a separate expression for this in Norwegian: “Taxation based on looking through the formalities” (Gjennomskjæring). Hence, despite the fact that most of the transfer pricing legislation is contained in one general section in the General Tax Law 1999, which also includes a reference to the OECD Transfer Pricing Guidelines, many of the BEPS recommendations have been deemed part of Norwegian tax legislation for a long time. To some extent, the recommendations have been used to tighten up the Norwegian tax legislation, but there are also elements that have been inspired by the BEPS recommendations, including the following.

• General interest limitation rules related to loans between related parties have been effective since 2014. This should be assessed against the background that interest costs are generally deductible, regardless of whether or not they are related to any income-generating activity or business activity. Also, general interest limitation rules for loans from third parties were implemented in 2019. Furthermore, petroleum activity has been subject to interest limitation rules with respect to Special Tax for many years.
• For hybrid mismatch situations, dividends are not tax-exempted for the shareholder if the distributing company is entitled to a tax deduction for such distribution.
• Changes in the definition of when a company is resident in Norway were made in 2019, in order to prevent companies from having dual residencies or no residency.
• To a limited extent, Norway is party to the MLI (see 4.3 Use of Treaty Country Entities by Non-treaty Country Residents). The limited participation is not because Norway does not want to impose changes to its double taxation conventions, but rather because Norway prefers direct negotiations as the basis for direct amendments to double tax conventions, in many situations. Also, with respect to the Nordic countries, there is already a multilateral double taxation convention in place, in which Norway prefers to include the necessary amendments directly.

The general governmental attitude towards BEPS in Norway is clearly favourable. This is partly because the Norwegian fiscal authorities welcome international support for principles that have for a long time been either formal legislation or a general position of the authorities. For example, the BEPS recommendations also represent a source of support for even tighter specific regulations related to interest limitations.

International tax has a high public profile in terms of individual histories being presented by the press (eg, “Panama papers” and specific cases), but it is probably fair to say that the general public does not seem very concerned about the concept of international tax, nor challenges related to it. Politically, there is clear attention on issues related to multinationals and the digital economy as a potential threat to the Norwegian tax base. During 2022, there was quite a lot of attention to HNWIs emigrating from Norway to jurisdictions with no or lower wealth tax.

Norwegian governments (being coalitions from either the conservative/centre side or the labour/left side) do not appear that interested in making the Norwegian tax system competitive, beyond trying to avoid it becoming uncompetitive. Accordingly, Norway will remain a high-tax jurisdiction with very few tax incentives. The general postulate is “a broad tax base and a low, but not (among) the lowest, tax rate”. Consequently, in 2019 the Norwegian corporate tax rate was reduced from 28% to 22%, with no immediate proposals to change it in any way.

The tonnage tax system was introduced to deter the Norwegian shipping industry leaving Norway. This is formally a system with limited duration, but it is difficult to see the system being abolished. However, an expert report in late 2022 suggested that it should be abolished, though so far with no such proposals from politicians.

Presumably, a fair statement is that investments into or from Norway are normally made despite the tax system and not because of it.

Because Norwegian tax legislation and practice are largely based on realities rather than formalities, the use of hybrid instruments to achieve tax objectives has probably been limited. The reasoning presented by the BEPS initiative appears to be in line with the general view of the Norwegian tax authorities. Accordingly, legislation stating that dividends are not tax-exempted for the shareholder in Norway if the distributing company is entitled to tax deduction for such distribution has already been implemented. In addition, changes in the definition of when a company is resident in Norway were implemented in 2019, preventing companies from having dual residencies or no residency. It is also expected that the Norwegian authorities will pursue this issue actively when negotiating new or amended double taxation conventions.

Primarily, Norway has a tax system that is based on global income, although there are certain elements that are territorial in scope. Typically, interest costs related to property or activity abroad that is exempted from Norwegian taxation under either domestic legislation or double taxation conventions are not deductible against income subject to Norwegian tax. Allocation rules – or more often principles – are important in this respect, but these rules are not part of the general interest limitation rules referred to under 5.7 Constraints on Related-Party Borrowing and 9.1 Recommended Changes; they are more a result of symmetry and neutrality considerations, which have for a long time been important principles on which the Norwegian tax legislation has been developed. The interest limitation rules have not had any significant effect on the level of investments in and from Norway, but rather on how they are structured.

Norway has had comprehensive CFC rules for decades. In general, the rules apply if 50% or more of a foreign company is directly or indirectly owned or controlled by Norwegian residents and the company in question is subject to taxes which are less than two thirds of the taxes the company would have been subject to if it were resident in Norway. Hence, the BEPS proposals in this respect represent very little change.

These rules apply regardless of substance in the CFC. Hence, the idea of having a sweeper CFC rule that could make offshore subsidiaries whose profits are taxed at a “low rate” vulnerable to CFC apportionment, regardless of the substance located in a particular jurisdiction, was implemented a long time ago. Finally, based on the concept of “taxation based on looking through the formalities”, CFCs with little or no substance would be vulnerable to Norwegian taxation, as if the company had been resident in Norway. There are examples of case law for this dating back to the early 20th century.

Due to the general concepts with respect to substance over form (see 9.1 Recommended Changes) and the rather aggressive transfer pricing approach regularly seen from the Norwegian tax authorities, it is difficult to see the BEPS initiatives on double taxation convention limitations of benefit or anti-avoidance rules having any significant impact on taxation in Norway.

As noted previously, it is difficult to see the proposed transfer pricing changes initiating any radical changes in Norway. Norwegian tax authorities have referred to the proposals as being in line with their understanding of the present situation in Norway.

Norway has a long tradition of transparency. In addition, the companies in question have long been required under Norwegian tax legislation to report their direct activity abroad. In addition, comprehensive CFC regulations have been in place for a long time. Hence, country-by-country reporting has already been introduced and does not represent anything fundamentally new.

There has been a lot of discussion on this topic in Norway, but very little (if anything) has been presented as firm proposals by the authorities. Partly due to the fact that Norway is a small country with a small but very open economy, Norwegian authorities seem to await EU initiatives and will not implement unilateral rules on this matter. Many of the issues and problems discussed with respect to digital economy businesses operating largely from outside the Norwegian jurisdiction are not necessarily fundamentally new to a country that has a long history of inbound investments.

See 9.12 Taxation of Digital Economy Businesses.

There are no special provisions dealing with the taxation of offshore intellectual property in particular. Ordinary rules apply, relying on Norwegian CFC rules and general transfer pricing measures such as the arm’s-length principle.