Norway Tax Agency Clarifies Tax Treatment of Cross-Border Parent-Subsidiary Merger, Lapse of Intra-Group Loan

The Norwegian Tax Administration April 14 posted Binding Advance Ruling No. 15/2025, clarifying the tax treatment of a cross-border parent-subsidiary merger and the lapse of an intra-group loan with unrealized foreign exchange gains. The taxpayer, a Norwegian parent company, planned to merge with its wholly owned nonresident subsidiary and sought confirmation that the merger would be tax-free and that the loan’s lapse wouldn’t trigger taxation. Upon review, the Tax Directorate clarified that: 1) the merger would qualify as a tax-free cross-border merger under Section 11-11(6) of the Taxation Act; 2) the intra-group loan would lapse upon merger because the creditor ...