Proposed change to Norwegian tax rules on currency losses for intragroup receivables

Losses on receivables between related companies are generally not deductible under the Tax Act Section 6-2, while currency gains remain taxable. This creates an asymmetry in the tax treatment of the currency element. The Ministry proposes to address this imbalance by amending the Tax Act Regulation Section 6-2-2, to allow deduction for currency losses on intragroup receivables to the same extent that currency gains are taxable.

The proposed rule recognises that currency fluctuations are often beyond companies' control and that the currency element should be treated separately from the underlying receivable. This approach aligns with Swedish tax practice and ensures symmetric and fair tax treatment of currency gains and losses, irrespective of whether the underlying receivable itself is deductible.

The Ministry expects no material administrative or economic impact from the change, and the amendment is therefore proposed to enter into force from 1 January 2025.

Companies with cross-border intragroup financing in foreign currencies should assess whether they have unrealised currency losses on such financing that could become deductible under the new rule. This may affect both current tax positions and future financing decisions between related entities.

The consultation paper can be found here. The consultation period ends 26 September 2025.