Tax

Our services

• Transaction-related tax advice, including structural documents, step plans, tax due diligence, deliberations and tax law assessments of various dispositions and events.
• Preventive tax advice: Through extensive tax dispute experience, we have gained a thorough knowledge of conditions that may be damaging in dispute matters and conditions that are crucial to have in place during the planning, implementation and execution stages.
• Transfer pricing, including choice of operational group structure, development of pricing models, preparation of intercompany agreements and transfer pricing documentation, as well as complaints and legal proceedings relating to all types of intercompany transactions, including sales of goods, services, IP, loan agreements and choice of capital structure.
• Tax treaties and international tax law, including tax treaty issues, negotiations on reciprocal agreements, exit tax upon moving, taxation of Norwegian-controlled companies in low-tax countries (NOKUS) and cross-border dividends.
• Foreign tax law: We take overall responsibility for tax consequences in other jurisdictions in close cooperation with Wiersholm's network of local law firms. An important part of our assistance consists of providing advice relating to the choice of local tax advisors (often in countries with entirely different legal traditions than Norway) and quality assurance of their advice.
• EEA tax law: We have assisted and been successful in a number of matters relating to discriminatory tax rules such as dividends tax, exit tax, NOKUS rules, wealth tax, transfer pricing, intercompany transfers and cross-border mergers. We assist at all stages, both with EEA submissions in amendment and appeal matters before Norwegian courts and before the EFTA Court, with complaints to ESA and communication with the Ministry of Finance.
• Administrative matters, ranging from unannounced tax audits to amendment matters and appeals. We regularly assist in a large number of administrative tax matters. Our tax lawyers have very extensive experience in this field, ranging from procedural issues, case management, choice of strategy and positioning for court proceedings.
• Judicial procedure: We possess extensive litigation skills and regularly litigate tax matters before the district courts, the courts of appeal, the Norwegian Supreme Court and the EFTA Court. We have assisted in a number of test cases pertaining to taxation of carried interest, the arm's length principle and transfer pricing, double taxation in Norway, piercing of the corporate veil, group contribution, value-added tax, dividends in contravention of the EEA, NOKUS, group contributions and wealth tax rules, the shipowner tax matter relating to unconstitutional retrospective legislation, duty of confidentiality and the group tax action relating to property tax in Oslo. Three of our tax lawyers are admitted to the Norwegian Supreme Court.