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Arntzen de Besche has written the Norwegian chapter in Baker & McKenzie’s publication “The Transfer Pricing Handbook | Europe 2015»
In 2012, total transfer pricing adjustments in Norway amounted to NOK6.8 billion (approximately USD1 billion or EUR0.8 billion). In 2012, the adjustments totaled NOK7.2 billion (approximately USD1.2 billion or EUR0.9 billion).
Twelve agreements under the mutual agreement procedure (MAP) provided for by the tax treaties were concluded in 2013. At the close of 2013, there were four ongoing APA cases, out of which three have been concluded as of October 2014. One new APA request has been lodged.
Transfer pricing issues have been, and will continue to be a key area for Norwegian tax authorities. This applies in particular to the oil taxation authorities, as exploration and production activities on the Norwegian Continental Shelf (NCS) are subject to a 78 percent marginal tax rate, and most of the companies on the NCS are part of international groups. The oil taxation authorities have therefore been in the forefront in the transfer pricing area. Several of the larger transfer pricing court cases involve petroleum activity on the NCS. In 2013, the key focus for the Oil Taxation Office has been petroleum pricing and intragroup services.
Author: Anders Heieren
Published: April 2015
Publisher: Baker & McKenzie