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Norway Introduces New GAAR from 1 January 2020

14 January 2020

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Approved Changes

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Norway

Norway has introduced a new general anti-avoidance rule (GAAR) with effect from 1 January 2020. The new GAAR is provided in section 13-2 of the Tax Act and includes that avoidance (circumvention) exists where: The main purpose of a transaction or series of transactions was to obtain a tax benefit; and After an overall assessment, it is determined that the transaction(s) cannot be used as the basis for taxation. The overall assessment includes an assessment of: The intrinsic business values and economic effects of the transaction(s) other than tax benefits in Norway or abroad; The size of the tax benefit...