Norway Introduces New GAAR from 1 January 2020

Norway has introduced a new general anti-avoidance rule (GAAR) with effect from 1 January 2020. The new GAAR is provided in section 13-2 of the Tax Act and includes that avoidance (circumvention) exists where:

• The main purpose of a transaction or series of transactions was to obtain a tax benefit; and
• After an overall assessment, it is determined that the transaction(s) cannot be used as the basis for taxation.

The overall assessment includes an assessment of:

• The intrinsic business valu…