A request has been made to the EFTA Court from Oslo tingrett for an Advisory Opinion in the case of Fred. Olsen and others v Staten v/Skattedirektoratet.
A few of the questions are: Do trusts as a form of establishment fall within the scope of the freedom of establishment provided for in Article 31 of the EEA Agreement? Does the continuous wealth taxation of the beneficiaries for the trust's assets and taxation at a rate of 1,1 % constitute a restriction pursuant to Article 31 and/or Article 40 of the EEA Agreement — and can this be invoked by the beneficiaries in a trust as described in section 2 of the request for an advisory opinion?
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