Anders V. Heieren
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In an Oslo City Court ruling dated 30 June 2014, the taxable income of a Norwegian operating subsidiary of a major international oil company was increased by NOK 342 mill (USD 52 mill) covering the years 2003-2008.
The increase was due to a limitation of tax deduction for costs charged by the parent company for such as asset management, planning, R&D and administrative services. The allocation key applied by the parent company was found to result in charges which clearly exceeded the documented benefit received by the Norwegian subsidiary.
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