The question in the case was whether a Norwegian company had received an arm’s length price when selling gas to a French company in the same group.
Judgement of the Court of Appeal
The Court of Appeal came to the conclusion that the agreed transfer price had not been at arm’s length and this meant a reduction in income for the Norwegian company. The Appeal Board for Petroleum Tax’s decision was upheld.
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LG-2021-8008-–-UTV-2022-697-ORG