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Norway - On June 15, 2012, Norwegian Parliament accepted the following fiscal measure with respect to exit tax. This was necessary after the decision of the ECJ in National Grid Indus. These changes have effect from 15 May 2012. That was the day of the presentation of the measures to the Norwegian Parliament.

-	There is an interest charge on the exit tax which has been deferred. It is charged until the date of realization of the asset. The interest is set annually on 1 January of the relevant year (the rate for 2012 is 2.75%);
-	a taxpayer has to provide a guarantee for the deferred exit tax, even though there is a tax treaty providing for exchange of information and the assistance in the collection of taxes in force between Norway and the country to which the taxpayer moves;
-	exit tax liability lasts indefinitely (currently, the exit tax liability is extinguished if the assets are not alienated within 5 years);
-	the deferral is restricted to apply only when the taxpayer moves to another EEA country;
-	the exit tax is not reduced even though the value of the asset decreases (currently, the tax liability may be reduced provided that the value of the assets decreases after the exit taxation is calculated);
-	no tax credit can be claimed for any tax paid in the other state against the exit tax liability in Norway; and
-	losses can be claimed in the year of exit (currently, only at the date of exit from Norway).

 

 

 

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