Section 6-2 third paragraph of the Tax Act precludes deductions for losses on receivables between associated companies. In Section 6-2-2 of the Regulations pursuant to the Tax Act (FSFIN), the Ministry of Finance stipulates what should be deemed as an associated company in the context of the new provision. The rule does not preclude companies from claiming deductions for losses on:
- trade debtors
- receivables which the lender has previously recognised the value of as income
- merger receivables
- divestment receivables
- receivables to banks and finance companies, etc. where the receivable forms part of the creditor’s ordinary lending activity
Entering receivables from associated companies in the forms
Receivables from associated companies do not give entitlement to deduct losses in connection with tax assessment. No temporary differences normally arise relating to such receivables. When you complete RF-1217 “Forskjeller mellom regnskapsmessige og skattemessige verdier” (Differences between accounting and tax values - in Norwegian only), you should not enter the accounting value of such receivables under item 42. You should also not enter the fiscal value of such receivables under item 43.