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Nyhetsbrev - Interest deduction limitation proposed in Norway

On the 11th of April 2013 the Norwegian Ministry of Finance published a legislative proposal and invited public submissions on the introduction of an interest deduction limitation for loans between related persons.

A related person is defined as a lender directly or indirectly controlling 50% or more of a borrower, or a borrower directly or indirectly controlling 50% or more of a lender. The paper proposes to limit the deductible amount of interest to 25% of an adjusted taxable income, when paid to a related person. The adjusted taxable income is taxable income increased by net interest costs and tax depreciations, similar to EBITDA. The taxpayer will not be able to deduct interest payments to the extent such expenses exceed 25% of the mentioned EBITDA. Companies whose net interest costs are below NOK 1 million are expected to be exempt.

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