In this note, the author provides details of the Budget for 2009. The most important changes are to net wealth tax, gift and inheritance tax, the exemption method in respect of the dividends and gains of corporate taxpayers and exit taxation. There are also changes to tonnage tax and the customs regime. Unless otherwise indicated, the changes apply from 1 January 2009.
In this first part of a two-part article, the author focuses on the technical aspects of the similar participation exemption regimes in the Nordic countries by first discussing the scope of the regimes.
In this second of a two-part article, the author concludes his discussion on the scope of the participation exemption regimes in the Nordic countries started in part 1. A detailed consideration of the relevant anti-avoidance rules forms the subject matter of the remainder of part 2.
The tax implications of the tax reforms contained in the Norwegian Budget for 2005 with regard to company and shareholder taxation are examined
In November 2003 the impact of the fundamental freedoms under the European Economic Area (EEA) Agreement on direct taxation was considered by a Norwegian court for the first time. A look at the implications of the decision.
The details of the new tonnage tax regime, created in order to safeguard Irish shipping, are outined.
The Norwegian Supreme Court's judgment in Ptarmigan, concerning the liability of beneficiaries of a discretionary trust established in Liechtenstein for income tax on the current income and gains of the trust under the Norwegian CFC legislation, is commented on by the author.
The EEA agreement, entered into in May 1992 for the purpose of including the EFTA member states in the common market, and its corresponding bodies (the Council, the Committee, the EFTA Surveillance Authority and Court) are examined in the context of the agreement's impact on direct taxation.
Retroactive legislation is not a rare phenomenon in Norwegian tax law. In a case note the author analyses a Supreme Court decision on the issue.
In an overview of the new parliamentary programme, the author focuses on consultation documents and plans for business taxation and VAT.
The author discusses changes in the FA 1999 and the FA 2001 to the rules governing the acceptable distribution policy exemption applicable to dividends paid by controlled foreign companies.