Norway v. ConocoPhillips Skandinavia
Norway v. ConocoPhillips Skandinavia
Jurisdiction
Norway, Court of Appeal
Summary of Facts
The case involved a loan agreement between ConocoPhillips Norway and its subsidiary, with the tax authority challenging the interest rate as not being at arm’s length.
Key Issues
Whether the interest rate on the loan followed the arm’s length principle.
Decision and Reasoning
The court ruled in favor of the tax authority, stating that the interest rate should have been lower and aligned with the arm’s length standard.
Importance and Implications
This case highlights the scrutiny of inter-company financial arrangements and the importance of adhering to market-based interest rates.
