Norwegian Tax Agency Clarifies Taxation of Liquidation Payments for Nonresident Shareholders Under Corporate Restructuring

The Norwegian Tax Administration Sept. 11 posted online a Binding Advance Ruling No. 17/2024, clarifying tax treatment for a nonresident shareholder reorganizing a Norwegian holding company. The taxpayer, a nonresident individual, sought clarification on whether a series of transactions, including capital reduction in an investment company, demerger of a holding company, and subsequent liquidation of a newly established company, were improperly aimed at withdrawing funds tax-free. The Tax Administration clarified that: 1) the main purpose of the entire transaction sequence was to avoid paying Norwegian dividend tax; 2) the technical arrangements were considered tax avoidance under the Taxation Act, and ...