Discretionary assessment of tax in cases of associated enterprises

The Supreme Court's Appeals Selection Committee decided on 27 October 2025 that the appeal against Borgarting Court of Appeal's judgment 7 May 2025 will be heard by the Supreme Court.

The State represented by the Petroleum Tax Office
(Counsel Kaare Andreas Shetelig)

v.

Orlen Upstream Norway AS
(Counsel Andreas Bullen)

Discretionary assessment of tax in cases of associated enterprises. Issue of whether the Court of Appeal had authority to issue a directive concerning the determination of interest rates on intra-group loans in favour of the taxpayer. Section 13-1 of the Tax Act.