Dato og tidspunkt

20.05.2019 08:00-11:00




Thommessen and Conyers team up to host a seminar on the background and practical implications of both the new Norwegian rules and the new offshore requirements with particular focus on Bermuda's economic substance regime. The seminar will discuss the implications for various companies within the shipping and offshore industry, private equity, asset management among others.


  • 08.00 - 08.30 Registration and network breakfast
  • 08.30 - 08.40 Introduction | Henrik Hagerg, Thommessen
  • 08.40 - 09.15 Norwegian tax residency | Finn Backer-Grøndahl, Thommessen
  • 09.15 - 10.00 Offshore/Bermuda economic substance requirements | Marcello Ausenda, Conyers
  • 10.00 - 11.00 Networking


New Rules for Determining Tax Residency

Norway recently introduced new rules for determining tax residency for companies registered in Norway and outside of Norway. Prior to the change, the place of effective management at board level was the key factor in the assessment. The new rules also refer to the place of daily management and other factors related to the company's organization and  business activities. The key question is whether the new rules will mean that non-Norwegian companies will be considered resident in Norway for tax purposes as a consequence of daily management (CEO, CFO etc) or other functions being performed in Norway.

At the same time, the EU has put substantial pressure on offshore jurisdictions including Bermuda, the British Virgin Islands, the Cayman Islands, Guernsey and the Marshall Islands to implement local economic substance requirements as a  condition for companies in such jurisdictions to continue to benefit from beneficial tax regimes, such as zero/tax neutral taxation. In order to comply, Bermuda and other offshore jurisdictions were forced to introduce local economic substance requirements by 31 December 2018. Understanding these new local economic substance requirements and how they will apply in practice is fundamental to navigating the pitfalls and potential consequences of falling foul of the new rules.  

This joint seminar will provide a unique opportunity to further understand the multi-jurisdictional interplay between the Norway tax regime and the offshore economic substance regimes with particular focus on Bermuda.

Please click here to register


Free of charge


Thommessen office Haakon VII's gate 10, Oslo