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Norwegian Tax Appeals Board Holds PE May Not Deduct Costs for Use of Parent Company's Employees or Assets

16 May 2019

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Approved Changes

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Norway

On 9 May 2019, a decision of Norway's Tax Appeals Board was published concerning the allocation of costs to a permanent establishment in Norway. In particular, the decision addresses whether a deduction may be granted for the use of the parent company's employees and assets in determining taxable income of a permanent establishment. The permanent establishment at issue was constituted by a foreign company that performed maintenance and development service in Norway that involved the assignment of personnel for a duration exceeding 12 months. In 2014, the Norwegian tax office informed the company that it was considered to have a...