Norwegian Tax Administration Issues Ruling on VAT for Company Reorganization and Real Estate Separation

• The Norwegian Tax Administration issued Binding Advance Ruling No. 12/2024 on VAT rules for company reorganization.
• The company owners planned to separate real estate into a new company and operate through a holding company.
• The plan involved creating a holding company and two subsidiaries: Operations 2 and Property.
• The Tax Directorate concluded the fission-merger with Operation 2 is not an adjusting event.
• The demerger requires an output VAT calculation for the company.
• Operation 2 should not be VAT-registered during the taxable activity transfer.
• No VAT adjustment agreements are needed as capital goods will be transferred back to the company.

Source: news.bloombergtax.com

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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