Worldwide Tax Summaries--Norway(1999-2000)(part1)

Worldwide Tax Summaries--Norway(1999-2000)(part1)

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There have been no significant tax or regulatory developments during the past year.

Income tax/ Corporate tax is assessed a rate of 28%.Special oil tax / Companies involved in the production or pipeline transport of oil and gas are liable to income tax at 28%plus a special oil tax at a rate of 50%. The speCIAl oil tax is calculate according to the provisions of the petroleum Tax Act.

All companies established according to Norwegian law and incorporated in Norway are regarded as resident in Norway. The place of central management must be situated in Norway.

Value-added tax / There is a value-added tax of 23%. An investment tax of 7% is levied on most purchases for which VAT may be claimed as a deduction (credit ) for refund . Investment tax is not levied on goods for resale and capital assets used in production and mining activities.

Capital taxes / Companies (ASs and ASAs) are no longer liable to capital tax.

Branch income is taxed at corporate rates. Branches of foreign limited liability companies are not subject to capital tax.

Inventory valuation/ Inventory is valued at cost. Cost is normally FIFO. LIFO is not acceptable for tax purposes. Conformity between book and tax reporting is not required.

Capital gains/Capital gains realized in the course of a business activity are almost always regarded as taxable income . Sales gains in respect of real estate transactions are taxed regardless of whether they are incurred in connection with business activity. Losses can be offset against the taxpayer's other income.

Gains realized on both business-related and non-business activity are almost always regarded as taxable income. Sales gains in respect of real estate transactions are taxed regardless of maturity are regarded as taxable. For most binds acquired after May 10,1990 any gains realized at maturity are regarded as taxable income Realized losses will be eligible for corresponding deductions.

A safeguard against the double taxation of capital gains on shares has been introduced. This is the RISK (opening value adjustment) method, which takes into account tax paid on retained profits during the ownership period. The opening value of the share is to be adjusted according to changes in the company's retained earnings during the ownership period. Gains from the disposal of shares in foreign companies are to be taxed in full without allowing for opening value adjustments. The gain is taxed as ordinary income, i.e., at the rate of 28%.

Intercompany dividends / The imputation system applies for the taxation of company profits and dividends in order to avoid the double taxation of companies and shareholders. Under the imputation system, companies pay tax on both retained and distributed profit. In assessing tax on dividends received, credit is given for tax paid by the company on distributed profits. For this tax credit to apply, the dividends must originate from a company with general tax liability in Norway, and the recipient shareholder must be fully taxable in Norway for dividends received.

A Norwegian parent company (at least 10% ownership) will be allowed a deduction (credit ) from Norwegian taxes for underlying company tax paid on dividends received from a foreign subsidiary or sub-subsidiary . This deduction, together with any deduction for withholding taxes paid , may not exceed the Norwegian tax attributable to gross dividends. The same applies to a sub-subsidiary located in the same country as the subsidiary. The parent company must then own at least 25% of the sub-subsidiary to qualify for a deduction.

Dividends are taxed at the rate of 28%.

Foreign income / If double taxation is not avoided by a tax treaty with the country concerned, a Norwegian corporation is liable to Norwegian income tax on (1) foreign branch income and (2) foreign dividends when received.

Deduction for foreign tax may be claimed as an expense or as a credit against Norwegian tax payable on that income.

Stock dividends / Stock dividends are not taxable on receipt , provided that the dividends have been distributed in accordance with the tax and joint stock company acts.

Depreciation and depletion / For depreciation the declining-balance method is mandatory. The depreCIAtion rates given below are the maximum rates.

Office machines , etc.                                          30
Acquired goodwill / business value                               30
Trucks, lorries, buses, taxicabs, vehicles for the disabled                                          25        
Cars, tractors, other vehicular machinery, instruments,       
Fixtures and furniture, tc.                                      20
Ships, vessels, offshore rigs, etc.                                20
Aircraft, helicopters                                            12
Buildings and construction, hotels, hostels, inns, etc.            5
Office buildings                                                2
Special depreciation rules apply to assets that are moved in and out of Norwegian jurisdiction.Oil companies must apply straight-line depreCIAtion over six years on offshore installations.

Depletion allowances do not exist. Where the special oil tax of 50% is calculated, a special deduction in addition to normal depreciation is allowed (uplift). The uplift is calculated as 5% of the cost of depreCIAble assets used in production or pipeline transport and is allowed for six years.

Net operation losses / A loss carryover for up to ten years is available (for entities liable to the speCIAl oil tax, 15 years). Losses incurred in the year of ceasing business may be carried back for a period of two years. If a loss is incurred in the next to last year, it may be carried back to the preceding year.

Payments to foreign affiliates / Royalties and service fees are freely transferable to related companies abroad, provided calculation is based on arm's-length terms. As from 1991, interest paid to a recipient that is resident abroad is deductible only if loan documentation satisfies the requirements of the Ministry of Finance.

Taxes / No taxes are deductible in determining corporate income.

Goodwill / Acquired goodwill may be depreCIAted by the declining-balance method at a maximum of 30% per annum. However, this does not apply to companies engaged in oil-and gas-producing activities subject to the Petroleum Tax Act.

Income taxes are assessed on companies individually, not on a
consolidated basis. This may be avoided through group contributions between Norwegian companies, provided common direct or indirect (including foreign) ownership is more than 90% . Group contributions are not deductible for companies engaged in oil-and gas-producing activities subject to the Petroleum Tax Act.

Assets may be transferred tax free between group companies at tax book value for tax purposes and at market value for financial book purposes. Payment in this respect must equal market value of the assets transferred for tax and finanCIAl nook purposes. The same applies to payment in shares . If the transferee at a later stage steps out of the tax group and is still the owner of the transferred shares, the transferor will be taxed for the difference between the tax book value and the market value of the assets.

Joint stock companies that own or lease ships or contracting vessels in traffic or drilling rigs can choose a special shipping company taxation so that their net income from their own and rented vessels will be exempt from taxation. The employees of the company will not be included in the scheme. Net finanCIAl income is taxed on a regular basis. In addition, there will be a tonnage duty payable according to the Law of June 19,1964, number 20, section 7a , regarding measurement of vessels.

Norway does not levy withholding taxes on payments of royalties and interest. Dividend payments are subject to withholding tax at the following rates.


RECIPIENT                                      REGUEAR     PARENT/

                        %             %
Nontreaty                                       25             25
Treaty :
Australia                                      15             15
Austria                                        15             5(1)
Azerbaijan                                     15             10(2)
Barbados                                      15             5(3)
Belgium                                       15             5(1)
Benin                                         18             18
Brazil                                         15             15
Bulgaria                                       15             15
Canada                                        15             15
China, P.R                                     15             15
Croatia                                        15             15
Cyprus                                         5              0(4)
Czech Republic (5)                              15             5(1)
Denmark                                       15             0(3)
Egypt                                         15              15
Estonia                                        15             5(1)
Faroe Islands                                  15             0(3)
Finland                                       15              0(3)
France                                        15            5(3)/0(1)
Gambia                                       15               5(1)
Germany                                      15               5(1)
Greece                                       20               20
Hungary                                      10               10
Iceland                                       15               0(3)
India                                         25              15(1)
Indonesia                     &nbs

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电 话:(010)- 52086638 51095615
传 真:(010)- 52086636
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