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Norway
COPENHAGEN-The Norwegian Supreme Court Jan. 11 declined to hear an appeal by Cytec Overseas Corp. and Cytec Norge GpAS, vindicating methods used by Norway's tax authority, Akershus Fylkesskattekontor, in valuing a Norwegian limited liability company after it transferred its account and risk to a foreign partner company. [Cytec Overseas Corp. and Cytec Norge GpAS, Supreme Court, case nr. 2007/1792, decision 1/11/08]
The decision confirms a Sept. 26, 2007, ruling by the Eidsivating Court of Appeal, which stated that the tax authority was within its right to reach an independent valuation.
The case referred to events in 1999, when Cytec Overseas Corp. and Cytec Norge GpAS were partners in the Norwegian limited partnership Cytec Norge KS. That year, Cytec Norge KS stopped manufacturing automotive goods in its own right and began manufacturing on contract for a Dutch company that was part of the U.S.-based Cytec group. The fact that the company's account and risk had been switched to the Dutch company, and the fact that the Norwegian company's economic performance...