The Finance Minister opened a public hearing regarding the corporate tax residency rules under section 2-2 of the Tax Law (Skatteloven) on 16 March 2017. There is no definition of residence is available now in the Norwegian tax legislation for legal entities. Generally the place of residence depends on the location of the central management and control of the company basically where the central business decisions of the company are made. However, a company is normally deemed to be a resident if it is incorporated under Norwegian law.
According to the hearing, section 2-2 of the Tax Law should be amended and the term “residence” would include companies established in Norway and companies having their effective management in Norway. The amendments will be effective from fiscal year 2018.
