Cross border tax system: A study on Telenor

Introduction:
Now a days, borderless transection made it easy to make investment throughout the world. But taxation of
the resulting investment income is therefore a significant and critical problem for both the host country in
which the investment is made and the home country from which the capital comes (Article 1 ).
Countries differ in their taxation of foreign, as well as domestic, profits generated by companies
domiciled (Legal residence or site of incorporation of the parent company) within their borders
(Colliens). Thues, a costly factor of production that differs across geographic jurisdictions, is often cited
as a culprit to maintaining global competitiveness (e.g., Merrill and Patrick, 1992). Moreover, In a world
of increasing capital mobility, these differences in tax burden may influence investment decisions by
attracting FDI to locations where the pre-tax cost of producing goods is higher but the production cost is
lower in the presence of relatively low tax burden, possibly resulting in tax-induced distortions in the
allocation of capital flows (Article 2).

We studied Telenor Group to examine their cross border transection and detail taxation on them
or their profit taxation throughout the world. Generally we think tax is only imposed by one
jurisdiction where the transection took place. But what if the transection is a cross border
transection and comes under more than one jurisdiction? In other word what if the home country
and host country is different? Will that taxpayer ended up with double taxation or not? To find
out the answer we studied Telenor company to reach a conclusion.--------

Introducing Telenor
Telenor Group is a leading telecommunications company across the Nordics and Asia with 182
million customers and annual sales of around USD 12 billion (2019). Its headquarter is at
Fornebu in Baerum, close to Oslo, continuing operations worldwide, but focused in Scandinavia
and Asia. It has extensive broadband and TV distribution operations in four Nordic countries,
and a 10-year-old research and business line for Machine-to-Machine technology. Telenor owns
networks in 9 countries.

Telenor is listed on the Oslo Stock Exchange and had a market capitalization in November 2015
of kr 225 billion, making it the third largest company listed on the OSE after DNB and Equinor
(previously known as Statoil).