2013–2026
Strawberry Fields Tax Case: Withdrawals of Approximately NOK 795 Million and Anti-Avoidance Rule Applied, Supreme Court Appeal Refused
Following the acquisition of Oslo Properties/Strawberry Fields, a substantial paid-in capital position enabled withdrawals which Stordalen regarded as tax-neutral. The authorities argued that the acquisition's principal purpose was to exploit this tax position and that the former anti-avoidance rule should apply. The courts largely upheld the authorities' position, with more than NOK 400 million at stake over the years concerned.
- State of the evidence
- tax and judicial decisions documented; appellate judgment became final after Supreme Court refusal
- Legal status — source text
- on 24 March 2026, the Supreme Court's Appeals Selection Committee refused to hear the case; the adverse Borgarting judgment of 24 November 2025 became final
- Attribution
- responsibility at the level of Stordalen's companies and tax structuring; must not be characterised as criminal fraud
Sources · 3
- [1]
- [2]
- [3]
Last verified: 31 August 2026
