Norway - Dell Wins Important Agency Permanent Establishment Case
- J. Bjerke; S. Søgaard
- International Transfer Pricing Journal, 2012 (Volume 19), No 3
- 4 May 2012
Dell recently won an important tax case before the Norwegian Supreme Court regarding the interpretation of the agency permanent establishment rule under the Norway–Ireland treaty. This article analyses the Court's decision, as well as those of lower courts, and considers the potential future impact of the Court's decision.