On 1 June 2022, the EFTA Court delivered its judgement in the case of PRA Group Europe AS v the Norwegian Tax Authorities (E‐3/21) concerning the lawfulness of the Norwegian interest limitation rules (as they read from 2014 to 2018) under the freedom of establishment in the EEA Agreement Article 31. The EFTA Court concluded that the combination of the Norwegian interest limitation rules and group contribution rules were in breach of the EEA Agreement as they enabled Norwegian companies having domestic group companies (common ownership of more than 90%) to lessen or
remove the effects of the Norwegian interest limitation rules. This possibility was not available for Norwegian entities without domestic group companies.
International Tax and Treasury