Norway Tax Agency Clarifies Initial Value, Time of Valuation of Shares Received From Debt-to-Equity Conversion

The Norwegian Tax Administration April 23 posted online Tax Appeals Board Decision No. SKNS1-2024-96, clarifying the determination of initial value and valuation timing for company shares issued in a partial debt-to-equity conversion. In 2015, the taxpayer, an individual and the company’s sole shareholder, converted part of a debt claim into equity, receiving 35 shares, and purchased 5 additional shares. The Tax Office ruled that the acquisition cost of the 35 shares matched the increase in equity from the claim’s value at a 2015 general meeting. The taxpayer appealed, arguing that the full claim value and asset appreciation should factor into ...