The dispute in this case was the price paid in 2013 for an intra-group transfer of intangibles.
In January 2013 the Swiss company Normet International Ltd acquired all the shares in the Norwegian company Dynamic Rock Support AS (now Normet Norway AS) for a price of NOK 78 million. In February 2013 all intangibles in Dynamic Rock Support AS was transfered to Normet International Ltd for a total sum of NOK 3.666.140.
The Norwegian tax authorities issued an assessment where the arm’s length value of the intangibles was set at NOK 58.2 million.
The Court of Appeal upheld the tax assessment issued by the tax authorities and rejected the appeal.