CELEX: E2007P0007
Language: en
Date: 2007-05-25 00:00:00
Title: Request for an Advisory Opinion from the EFTA Court by Stavanger tingrett dated 25 May 2007 in the case of Seabrokers AS v Den Norske Stat v/Skattedirektoratet (Case E-7/07)

13.12.2007   
            
            
               EN
            
            
               Official Journal of the European Union
            
            
               C 301/20
            
         Request for an Advisory Opinion from the EFTA Court by Stavanger tingrett dated 25 May 2007 in the case of Seabrokers AS v Den Norske Stat v/Skattedirektoratet
   (Case E-7/07)
   (2007/C 301/12)
   A request has been made to the EFTA Court by a letter of 25 May 2007 from Stavanger tingrett (Stavanger District Court), which was received at the Court Registry on 30 May 2007, for an Advisory Opinion in the case of Seabrokers AS v Den Norske Stat v/Skattedirektoratet, on the following questions:
   
               1.
            
            
               
                  Is it contrary to Article 4, 31 or 40 of the EEA Agreement to attribute, according to the principle of net income taxation, debt interest to the income abroad when calculating the maximum credit allowance?
               
            
         
               2.
            
            
               
                  Is it contrary to Article 4, 31 or 40 of the EEA Agreement to attribute, according to the principle of net income taxation, group contributions to the income abroad when calculating the maximum credit allowance?
               
            
         
               3.
            
            
               
                  Will the answer to question 1 and/or 2 be the same if the debt interest and/or the group contributions can only be linked to the business in Norway?