By Michael Vorndran, Nord Advisory AS, Oslo, Norway (First published on MNE Tax)
On 28 May the Norwegian Supreme Court issued a ruling in a transfer pricing case between the Shell group’s Norway subsidiary, A/S Norske Shell, and the Norwegian oil taxation office.
The case covered the 2007 to 2012 fiscal years and related to the intragroup charging of research and development (R&D) costs. The court held in favor of A/S Norske Shell.
A/S Norske Shell was involved in R&D during the income years by paying its share of costs to the Shell group’s centralized R&D center in the Netherlands and through its participation in local R&D projects in Norway.