Market Intelligence

Data centres face complex VAT considerations during construction and operation phases, with significant implications for input tax deduction and cash flow management. The classification of data centre arrangements as either VAT-liable services or exempt property leases fundamentally determines the VAT treatment, while pre-registration requirements and export rules add further layers of complexity that require careful planning and structuring.

The Norwegian Tax Appeal Board has issued four decisions applying the exemption from penalty tax for obvious arithmetic or clerical errors following the Supreme Court's Caiano ruling. These decisions demonstrate a taxpayer-friendly interpretation covering dropdown-menu errors, incorrect carry-forward losses, broken software links, and dropped pre-filled data, establishing a broader application of the exemption than previously anticipated.

Norway's Tax Commission has delivered its recommendations on exit tax reform, proposing relief measures including reduced dividend instalment rates and exemptions for temporary residents. Will these changes make it into the 2027 budget, or will they be deferred pending broader tax settlement negotiations?

The Norwegian Ministry of Finance has proposed significant amendments to the Section 10 Regulation governing asset transactions on the Norwegian continental shelf, introducing new documentation requirements, modified rules on contingent consideration, and expanded scope to include pipeline and infrastructure transfers. While the proposal offers increased flexibility in certain areas, it also eliminates seller carry provisions for decommissioning costs and imposes stricter timelines that may challenge commer

The OECD has released a discussion draft proposing revisions to Chapter VII of the Transfer Pricing Guidelines, focusing on intra-group services within multinational enterprises.

When Norwegian residents inherit foreign shares from parents living abroad, the tax basis they receive can differ dramatically from domestic inheritance rules. In some cases...