Norway Holds Irish Holding Company Board Meetings and EEA Branches Satisfy Substance Requirement for Dividend Exemption
On 4 May 2016, the Norwegian tax authority (Skatteetaten) issued a ruling on whether dividends paid by a Norwegian company to its Irish holding company would qualify for Norway's participation exemption for dividends paid to EEA/EU countries. In general, for the exemption to apply, real business (substance) requirements must be met and the structure must not be for purely tax reasons.
The hold…
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