Norway Tax Agency Clarifies Taxation of Cross-Border Corporate Restructuring Involving Merger, Relocation

The Norwegian Tax Administration April 9 posted online Binding Advance Ruling No. 4/2026, clarifying the taxation of a cross-border corporate restructuring involving a merger and relocation. The taxpayer, a Norwegian company, was part of an international group that planned a corporate restructuring, and sought clarification on whether the merger of a Dutch company into a Cypriot entity could be carried out tax-free, and whether the subsequent relocation of the Dutch company from Cyprus to Singapore would trigger taxable gains or be covered by the Norwegian exemption method. Upon review, the Tax Directorate clarified that: 1) the Taxation Act allowed tax-free ...