Executive summaryOn 22 September 2021, the Norwegian Ministry of Finance (the Ministry) issued a public consultation paper proposing amendments to the conditions for a tax neutral cross-border restructuring. The current rules provide for the possibility of carrying out a cross-border restructuring, including mergers, demergers and certain exchanges of shares, without triggering Norwegian taxation on a company or shareholder level, subject to certain conditions. One of the general conditions is the transaction is carried out in accordance with the principle of tax continuity in the countries involved and that all tax positions are unchanged for the shareholders and the companies that...