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Norway to Relax Tax Continuity Conditions for Tax-Free Cross-Border Reorganizations

24 September 2021

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Proposed Changes

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Norway

Norway's Ministry of Finance has launched a public consultation on a proposal for changes in the rules on tax-free cross-border mergers, demergers, and share exchanges, in order to simplify the rules and facilitate better organization of business activities. The rules on tax-free cross-border reorganizations would be amended in relation to the condition the transaction is carried out with tax continuity, which is meant to safeguard the Norwegian tax base by ensuring that the tax exemption on the transaction does not become final, but that taxation is instead postponed to a later tax-triggering event. The tax continuity condition currently applies at...