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Priority for Tax Claims Restored in Restructuring

Summary

  • Norway reinstates priority status for VAT and tax claims in restructuring proceedings
  • Temporary COVID-19 treatment as unsecured claims ends
  • Effective 1 July 2026, strengthening recovery position of tax authorities


Article

Norway has reintroduced statutory priority for certain tax claims in insolvency and restructuring proceedings, reversing temporary COVID-19 measures. The reform, adopted by the Storting, applies from 1 July 2026.

During the pandemic, tax claims—including VAT—were treated as ordinary unsecured claims to support corporate liquidity. With the expiry of these temporary rules, priority rights are reinstated under Section 9-4 of the Recovery Act (Dekningsloven).

The provisions grant preferential status to claims related to income tax, wealth tax, VAT, and social security contributions. Priority for withholding taxes remains unchanged.

The reform restores the pre-pandemic hierarchy and strengthens the position of tax authorities in insolvency procedures.


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