Norway Holds Irish Holding Company Board Meetings and EEA Branches Satisfy Substance Requirement for Dividend Exemption

On 4 May 2016, the Norwegian tax authority (Skatteetaten) issued a ruling on whether dividends paid by a Norwegian company to its Irish holding company would qualify for Norway's participation exemption for dividends paid to EEA/EU countries. In general, for the exemption to apply, real business (substance) requirements must be met and the structure must not be for purely tax reasons.

The holding company was organized in Ireland and held its board meeting twice a year. The board includes fou…