Norway Tax Agency Clarifies Tax Treatment of Planned Merger

The Norwegian Tax Administration May 11 posted online Tax Appeals Board Decision No. SKNS1-2025-68, clarifying the tax treatment of a planned merger. The taxpayers, parent companies of two tourism and real estate groups, sought clarification on whether merging to consolidate operations, financing, and destination-development activities wouldn’t cause the lapse of carried-forward losses and disallowed interest deductions. The Tax Office held that the merger was predominantly tax-motivated, and that the tax positions would, therefore, lapse. On appeal, the Tax Appeals Board found that: 1) the merger had valid business purposes, involving active groups with employees, ongoing operations, and concrete development plans, ...