Norwegian Data Center VAT Ruling: Split Treatment for Physical and Remote Services to Foreign Clients

• A Norwegian data center company sought a binding advance ruling on whether its services to a foreign client could be treated as a single VAT-exempt supply.
• The tax authority ruled that the services must be split: remotely deliverable services (like monitoring and data management) are VAT-exempt, while physical storage and infrastructure services are subject to Norwegian VAT.
• The company’s arguments that all services were consumed abroad and should be unified under the “principal supply doctrine” were rejected.
• The Tax Appeals Secretariat and Board found that the services had independent value and no single element dominated, so the unified service concept did not apply.
• The Board unanimously upheld the original decision, confirming only remotely deliverable services qualify for VAT exemption.

Source: skatteetaten.no

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.

---

---