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Norway's Tax Blog – tax, VAT and legal matters

Norway's Tax Blog – tax, VAT and legal matters

Eivind Faafeng Falck-Ytter Advokat | Direktør

Jeg heter Eivind Faafeng Falck-Ytter og er advokat i Advokatfirmaet PwC. Min jobb er å finne gode løsninger for næringslivet, hovedsakelig knyttet til internasjonal selskapsbeskatning, internprising og grenseoverskridende restruktureringer.

Skatteverdenen blir stadig mer internasjonal og kompleks. Ved kjøp og salg av varer og tjenester utenfor Norges grenser må norske virksomheter håndtere skatteregler både i utlandet og i Norge. PwC har kontorer i de fleste land og vi har et unikt nettverk av skatterådgivere som kan bistå med spesialkompetanse på de fleste områder. Jeg håper mine innspill kan gi deg en alternativ innfallsvinkel til ulike temaer enn hva tradisjonelle nyhetsbrev gir.

My name is Eivind Faafeng Falck-Ytter, and I work as a lawyer in PwC Tax & Legal Services. I assist clients in finding solutions mainly within international corporate taxation, transfer pricing and international restructurings.

I hope my contribution to the blog can provide alternative perspectives as a supplement to traditional newsletters.

If you have any questions, comments or input, feel free to contact me!


eivind.falck-ytter@pwc.com
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Country-by-Country notification in Norway

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 23-May-2017 10:13:53

Country-by-Country Reporting is implemented in Norway with effect from FY16. Deadline for submitting the FY16 report is December 31, 2017. The report shall be submitted electronically in an XML schema in the Altinn portal - a web portal for electronic dialogue between Norwegian business and government agencies.

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Areas of interest: Corporate tax

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Norwegian IKEA debt pushdown and transfer pricing case - english translation

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 17-Nov-2016 14:25:06

On October 18, 2016 the Norwegian Supreme Court made its decision in the IKEA case. The question was whether interest on inter-company debt, established as part of an inter-company reorganization could be denied for tax purposes pursuant to the anti-avoidance rule in section § 13-1 of the Tax Act (arm’s length principle), and/or the non-statutory anti-avoidance rule. 

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Areas of interest: Corporate tax

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Large businesses in the UK: publish your tax strategy

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 15-Jul-2016 10:00:00

On 24 June 2016 HMRC published an overview guide for large businesses (with a turnover above £200 million or balance sheet over £2 billion), on the requirement to publish their tax strategy before the end of the next financial year commencing after Royal Assent to Finance Bill 2016, and yearly thereafter.

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Areas of interest: Corporate tax

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IRS publish final regulations on confidential Country-by-Country Reporting

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 14-Jul-2016 10:00:00

On June 30 2016, the Internal Revenue Service published a document containing final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group. The final regulations affect United States persons that are the ultimate parent entity of a multinational enterprise group that has annual revenue for the preceding annual accounting period of $850,000,000 or more.

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Areas of interest: Corporate tax

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ECOFIN agrees EU-wide rules in Anti-Tax Avoidance Directive

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 12-Jul-2016 10:00:00

Political agreement on the Anti-Tax Avoidance Directive (ATAD) was reached by the EU Member States in the Council of the EU, meeting through its Economic and Financial Affairs (ECOFIN) Council on 17 June. The agreement was subject to certain reservations which expired on 20 June.

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Areas of interest: Corporate tax

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OECD Council approves incorporation of BEPS amendments into the Transfer Pricing Guidelines

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 11-Jul-2016 10:00:00

On 23 May 2016, the OECD Council approved the amendments to the Transfer Pricing Guidelines as set out in the 2015 BEPS Report on Actions 8-10 "Aligning Transfer Pricing Outcomes with Value Creation" and the 2015 BEPS Report on Action 13 "Transfer Pricing Documentation and Country-by-Country Reporting". These amendments provide further clarity and legal certainty about the status of the BEPS changes to the Transfer Pricing Guidelines, which were endorsed by the Council on 1 October 2015, by the G20 Finance Ministers on 8 October 2015, and by the G20 Leaders on 15-16 November 2015.

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Areas of interest: Corporate tax

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OECD releases standardised electronic format for the exchange of BEPS Country-by-Country Reports

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 08-Jul-2016 12:01:20

In a continued effort to boost transparency in international tax matters, the OECD has released its standardised electronic format for the exchange of Country-by-Country (CbC) Reports between jurisdictions – the CbC XML Schema – as well as the related User Guide. The CbC XML Schema is part of the OECD’s work to ensure the swift and efficient implementation of the BEPS measures, endorsed by G20 Leaders as part of the final BEPS package in November 2015.

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Areas of interest: Corporate tax

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OECD releases discussion draft on the multilateral instrument to implement the tax-treaty related BEPS measures

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 07-Jul-2016 15:17:53

The OECD has published a request for input related to the development of a multilateral instrument to implement the tax-treaty related BEPS measures.

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Areas of interest: Corporate tax

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How should the Country-by-Country Reporting rules be applied to investment funds?

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 06-Jul-2016 15:02:25

On June 29 2016 OECD released the report “Guidance on the Implementation of Country-by-Country Reporting: BEPS ACTION 13”. The report inter alia address the topic on how to apply CbC reporting to investment funds.

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Areas of interest: Corporate tax

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Introduction of OECD and EU Country-by-Country-reporting creates confusion

By Eivind Faafeng Falck-Ytter Advokat | Direktør , 04-Jul-2016 15:20:43

Following the publication of the final reports of the BEPS project in October 2015 OECD member countries around the globe are working on implementing OECD country-by-country reporting into domestic legislation. The European Union is no exception and votes in favor of amending the directive on exchange of information to adapt to the OECD regime.

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Areas of interest: Corporate tax

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