Norway - Commissionaire Structure as an Agency Permanent Establishment – Uncertain Profit Allocation
- T. Leegaard
- European Taxation, 2011 (Volume 51), No 6
- 4 May 2011
The author, in this note, critically examines the decision of the Borgarting Court of Appeals in the Dell Products case, wherein the Court held that the taxpayer, an Irish resident company, had an agency permanent establishment in Norway and consequently upheld the estimated assessment issued by the Norwegian tax authorities.