Control criteria:    1. There is deemed to be Norwegian control of a foreign company or undertaking if no less than one half of the ownership interests or capital of such company or undertaking are directly or indirectly owned or controlled by Norwegian taxpayers, at both the beginning and the end of the tax year.    2. There is also Norwegian control if the company or the undertaking were deemed to be Norwegian-controlled in the year before the tax year, unless less than one half of the ownership interests or capital are directly or indirectly controlled by Norwegian taxpayers, at both the beginning and the end of the tax year.    3. If Norwegian taxpayers own or control more than 60 percent of the ownership interests or capital as at the end of the tax year, there is Norwegian control irrespective of 1 and 2. Correspondingly, there is not Norwegian control if Norwegian taxpayers own or control less than 40 percent of the ownership interests or capital as at the end of the tax year.        Low-tax jurisdictions: Low-tax jurisdictions are jurisdictions in which the ordinary income tax on the overall profit of the company or undertaking is less than two thirds of the tax that would have been levied on such company or undertaking if it had been resident in Norway. The Norwegian tax rate in 2018 is 23 pct.