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State Aid

PR(09)65: Norwegian scheme on tax deductions for certain cooperatives incompatible with the EEA Agreement


Today, the Authority has closed its investigation of a Norwegian proposal to introduce a special tax deduction for certain cooperatives.

The Authority concluded that the scheme entails state aid which is incompatible with the state aid rules of the EEA Agreement. No recovery provisions are, however, necessary as the Norwegian authorities have not implemented the scheme, pending the Authority's final decision on the case.

According to the scheme, certain consumer cooperatives and cooperative building societies as well as cooperatives within the agriculture, forestry and fisheries sectors would be entitled to deduct allocations to equity capital from their income, thereby reducing the basis for their income tax. The Norwegian authorities have argued that the scheme would compensate the cooperatives for disadvantages with regard to access to equity capital.

The Authority considered that the scheme constituted state aid as the scheme would confer an advantage on the cooperatives covered by the scheme. Moreover, the relation between the alleged disadvantage for cooperatives and the tax benefit has not been made sufficiently clear by the Norwegian authorities. The Authority further assessed the compatibility of the scheme but concluded that it is not compatible with the EEA Agreement.

Today's decision does not deal with cooperatives in the agriculture and fisheries sectors to the extent that their activities fall outside the scope of the state aid rules of the EEA Agreement.


For further information, please contact:

Mr. Per Andreas Bjørgan
Director, Competition and State Aid Directorate
Tel. (+32)(0)2 286 18 36, or

Ms. Marie Wiersholm
Senior Officer,
Competition and State Aid Directorate
Tel. (+32)(0)2 286 18 65


Brussels, 23 July 2009

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