ConocoPhillips Case: Implications in Norway and Beyond

In January 2010 ConocoPhillips Scandinavia AS (COPSAS) and Norske ConocoPhillips AS (NCOPAS) lost their transfer pricing case in respect of their participation in the ConocoPhillips group’s cash pooling system. This article sets out the facts of the case and the judgement of the Court of Appeal, and considers the wider implications of the case, both for Norway and internationally.