December 02
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Trajan Shipley
21st October 2021
Internal Market Tax

EFTA Court to rule on compatibility of rules on limitation of deductibility for debt interests with freedom of establishment

Official publication has been made today of a request for an Advisory Opinion of the EFTA Court (PRA Group Europe AS v Staten v/Skatteetaten, case E-3/21) concerning the compatibility with the right of establishment of Norwegian tax rules concerning the limitation on deductibility for debt interests.

The rules in question allow for group contributors from Norwegian companies (and not from investments by or in other EEA companies) to increase the maximum deduction for interests. This has the effect of increasing the entitlement to deduction of interests on debt to affiliated parties under the limited interest deduction rule.

The Oslo District Court has referred three questions for a preliminary ruling, asking whether there i


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