Loss of outstanding receivables where the receivable has changed its nature to financial assistance. Note in VAT notification, additional tax

The case concerns the determination of input VAT by NOK 418,478 and the imposition of additional tax by 20%, NOK 83,695, cf. the Tax Administration Act § 12-1 and § 14-3, cf. the Value Added Tax Act § 4-7 first paragraph

Questions about outstanding receivables have changed the nature of financing assistance with the consequence that the conditions for loss recognition with correction of the calculation basis for value added tax are not considered fulfilled, cf. the Value Added Tax Act § 4-7 first paragraph.

Question whether there is a basis for imposing additional tax.

The case also raises the question of whether there is a breach of convention in relation to the requirement that the question of additional tax shall be decided within a reasonable time, cf. ECHR Article 6 no. 1, cf. the Human Rights Act §§ 2 and 3.

The case is processed together with a complaint on org. No. […] A AS.

The case has been processed in the general department where there is a dissent. The case will therefore be processed in a large department.