Permanent establishments and allocation questions pertaining to them - judgements of the Norway Supreme Court

The Norway Supreme Court has, in a number of cases, been asked to clarify some issues relating to permanent establishments and the allocation questions pertaining to them. This article reviews the judgements of the Supreme Court that have addressed these issues. The judgements illustrate the basic attitudes underlying the Supreme Court's approach to these issues, which is notably characterized by a strong "substance over form" doctrine and a willingness to disregard the wording of tax treaties in favour of an interpretation based on other considerations.