Norway Supreme Court rules in favor of Shell subsidiary in transfer pricing dispute

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.

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