Atle Melø

The Norwegian parent company Elopak ASA received dividends of approximately NOK 200 million in each of the years 2010 and 2014 from its Swiss subsidiary. Up to and including 2009, the subsidiary was...

The general rule under Section 23-2 of the Norwegian National Insurance Act is that employer’s national insurance contributions must be calculated on salary payments. An important practical exception is set out in subsection nine of the provision: ...

DNB operates a branch in New York. The branch receives deposits on which DNB pays interest. Most of the deposited funds are transferred to DNB’s head office in Norway for onward lending. Under...

A company was financed through loans from its parent company in Luxembourg but was allowed to deduct only part of its interest expenses. The tax authorities applied the interest limitation rule for related-party loans set out in Section 6-41 of the Norwegian Tax Act, as it was...