Norway Tax Agency Posts Board Ruling Clarifying VAT Treatment of Transferring Development Projects to SPVs

The Norwegian Tax Administration Feb. 5 posted online Tax Appeals Board Decision No. SKNS1-2025-65, clarifying the VAT treatment of transferring development projects to separate project companies (SPVs). The taxpayer, a company, developed energy-related projects and transferred mature projects to SPVs through asset sales or demergers. The taxpayer sought clarification on the VAT treatment of these project transfers. The Tax Office held that the transfer didn’t qualify for a VAT exemption, contending that the projects didn’t constitute a standalone, ongoing economic unit that could operate independently. On appeal, the Tax Appeals Board upheld the Tax Office’s decision, finding that: 1) the ...