Torp Computing Group ASA

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INFORMATION MEMORANDUM
Merger of Komplett ASA and Torp Computing Group ASA
If a Foreign corporate shareholder is carrying on business activities in Norway and the relevant
shares are effectively connected with such activities, the shareholder will be subject to the same
taxation as a Norwegian corporate shareholder, as described above.
12.3.2 Capital gains tax
Foreign personal shareholders
Gains from the sale or other disposal of shares by a Foreign shareholder will not be subject to
taxation in Norway unless the Foreign shareholder (i) holds the shares in connection with the
conduct of a trade or business in Norway or (ii) has been a tax resident of Norway within the five
calendar years preceding the year of the sale or disposition (and whose gains are not exempt
pursuant to the provisions of an applicable income tax treaty).
Foreign corporate shareholders
Capital gains derived by the sale or other realization of shares by foreign corporate shareholders
are not subject to taxation in Norway.
12.3.3 Net wealth tax
Shareholders not resident in Norway for tax purposes are not subject to Norwegian net wealth tax.
Foreign personal shareholders can however be taxable if the shareholding is effectively connected
to the conduct of trade or business in Norway.
12.4 Inheritance Tax
Upon transfer of shares by way of inheritance or gift, the transfer may be subject to Norwegian
inheritance or gift tax. However, such transfer is not subject to Norwegian tax if the
donor/deceased was neither a national nor resident in Norway for tax purposes.
The basis for the computation of inheritance tax is the marked value at the time the transfer takes
place. The rate is progressive from 0 to 30 percent. For inheritance and gifts from parents to
children, the maximum rate is 20 percent.