- J. Christian Grevstad
- Partner / Attorney at Law / MBA
Christian has specialized in petroleum taxation on the Norwegian Continental Shelf, general corporate taxation, transactions and transfer pricing. He possesses extensive experience from roles within the public tax administration and as a legal advisor for enterprises of all sizes, as well as public institutions. He began his career at the Norwegian Tax Administration (The Tax Directorate), where he was promoted to Deputy Director and Head of the International Tax Department within a few years. He later served as Deputy Director at the Ministry of Finance in the Petroleum Tax Department.
Expertise
- Taxation of petroleum extraction
- Renewable energy, CCS, and seabed minerals
- General corporate taxation and company law
- Interfaces between different tax regimes
- International taxation and transfer pricing
- Taxation of transactions
- Requests for binding advance rulings
- Communication and disputes with tax authorities
Professional career
| Periode | Stilling |
|---|---|
| 2024 - > | Partner, Advokatfirmaet Energy & Tax AS (ex. Advokatfirmaet Norge Norway AS) |
| 2009 - 2024 | Partner, Advokatfirmaet Harboe & Co AS |
| 2005 -2009 | Head of PWC’s global tax services in more than 50 countries to multinational client |
| 2000 -2009 | Partner and head of energy taxation, Advokatfirmaet PricewaterhouseCoopers DA |
| 1993 - 2000 | Permanent member of the Oil Taxation Board (Oljeskattenemnda) |
| 1989 - 2000 | External legal advisor to the Directorate of Taxes (Skattedirektoratet) |
| 1999 - 2000 | Partner, Advokatfirmaet Grevstad ANS |
| 1988 - 1992 | External legal advisor to The Ministry of Finance |
| 1988 - 1990 | Deputy attorney, Advokatfirmaet Grevstad ANS |
| 1986- 1988 | Deputy Director at the Ministry of Finance, Petroleum Department |
| 1982- 1986 | Various positions, including Deputy Director and head of the International Departement at the Tax Directorate (Skattedirektoratet) |
Education
| År | Utdanning |
|---|---|
| 1990 | Lawyer, Admitted to the Bar |
| 1985 | MBA (finance), University of Bradford, UK |
| 1984 | Business Economist, BI Norwegian Business School, Oslo |
| 1982 | Cand.jur., Universitetet i Oslo |
Languages
Norwegian, English, Scandinavian languages, some knowledge of German and French.
Other activities
Played a key role in developing the framework for binding advance tax rulings for petroleum companies – subsequently adopted as general provisions for all taxpayers.
Primary responsibility for the development and operationalization of tax provisions regarding the transfer of production licenses on the Norwegian Continental Shelf (Petroleum Tax Act Section 10).
Primary responsibility for regulations concerning the tax treatment of unitization and re-unitization of production licenses on the Norwegian Continental Shelf.
Extensive experience spanning two decades, specializing in providing tax services to upstream petroleum companies operating on the Norwegian Continental Shelf.
Frequent speaker at industry forums on petroleum taxation, corporate tax, transfer pricing, and related legal disciplines.
Supervisor and examiner for Master’s theses in tax law at the University of Oslo and the University of Bergen.
Guest lecturer in tax law at the University of Oslo.
Selected publications and presentations
| År | Publikasjoner og foredrag |
|---|---|
| 2025 | Commentaries to the Petroleum Tax Act, Universitetsforlaget – Juridika |
| 2024 | Commentaries to the General Tax Act Section 13-1 (Transfer Pricing), Universitetsforlaget – Juridika (partly published) |
| 2010 – 2026 | Taxation of upstream activity on the Norwegian Continental Shelf |
| 2010 – 2025 | Regular speaker on the oil industry’s annual Petroleum Law Seminar (Petroleumsjuridisk seminar): - CCS and Tax – Catastrophy or opportunities - Cooperation agreements in change – Some Tax Issues - The Petroleum Tax Act in a Green Transition - Why a Neutral Petroleum Tax - Lessee’s improvements on Leased Production Facilities - Default by licensees – Tax - Natural gas sales' equivalent to the norm price – New reporting obligations and the Petroleum Tax Act's provisions on discretionary income assessment |
| 2016 – 2025 | Regular speaker on Offshore Norge’s Tax Seminar: - Petroleum Taxation and the general tax legislation - Tax liability for activities on the Norwegian Continental Shelf - Is the Petroleum Tax Act adapted for power from shore? - Lessee’s improvements on Leased Production Facilities - Loans between related parties – Substantiating the reduction in income - Electrification and tax |
| 2023 – 2024 | Speaker on the oil industry’s annual Solstrand Seminar: - CCS projects and seabed minerals - From tie-ins to wind power and CCS – Tax implications |
| 2009 – 2024 | Speaker on the annual tax seminar organized by Norsk forening for Oljeregnskap og -Skatt: - Capitalisation of costs in the engineering phase - Application of the arm’s length principle in the absence of comparable uncontrolled transactions - Loans between related parties – Interest margin - Secondary liability for decommissioning obligations upon the sale of licenses |
| 1985 | Transfer Pricing of Patents and Know How, MBA Master’s thesis, University of Bradford, UK |
For more than two decades, Christian has provided tax advises to companies engaged in petroleum extraction and pipeline transportation on the Norwegian Continental Shelf. His expertise encompasses issues related to activities subject to special petroleum tax, as well as ordinary corporate taxation. Furthermore, he has extensive experience in navigating the interface between petroleum production subject to special petroleum tax, and other activities, such as Carbon Capture and Storage (CCS), offshore wind power, and various forms of service provision and business development. Much of his knowledge and experience in this field is compiled in the Commentary on the Petroleum Tax Act, published by Universitetsforlaget/Juridika in 2025.
A key focus area for both petroleum production companies on the Norwegian Continental Shelf and enterprises in other sectors is transfer pricing of transfer of goods and services, intangibles, and financial transactions (including loans, deposits, guarantees, hedging and financial instruments). Throughout his career, Christian has worked extensively with transfer pricing in numerous contexts. As early as 1985, he prepared his Master’s thesis on the topic “Transfer Pricing of Patents and Know-How”. In 2024, he completed the commentaries on Section 13-1 (the primary Norwegian provision regarding transfer pricing) in the General Tax Act Commentary published by Universitetsforlaget/Juridika.
For seven years, Christian served as a permanent member of the government-appointed Petroleum Tax Board (Oljeskattenemnda). In collaboration with the Oil Taxation Office, the Board was responsible for the annual tax assessments of companies engaged in petroleum extraction and pipeline transportation on the Norwegian continental shelf.
As a Partner and Head of Energy Taxation at PwC Norway from 2000, Christian advised a wide range of petroleum production companies. His responsibilities also included managing and coordinating tax services for a major international client across more than 50 countries.
During his service at Advokatene Grevstad ANS, his work primarily focused on corporate tax and contracts related to marine seismic surveys in Norway and abroad, in addition to providing advisory services to the Norwegian Tax Administration, the Ministry of Finance, and private enterprises.
In his capacity as Deputy Director at the Ministry of Finance, and subsequently as an external advisor to the Ministry, he played a pivotal role in drafting the legislation and operationalize the tax treatment of direct and indirect transfers of petroleum production licenses on the Norwegian Continental Shelf (known as Section 10 of the Petroleum Tax Act). This also included primary responsibility for drafting the regulations governing the tax treatment of unitization and re-unitization of petroleum deposits. Furthermore, he spearheaded the development of the framework for Binding Advance Rulings for companies subject to special petroleum tax – a regulatory framework that was later made applicable to all taxpayers seeking clarification on the tax implications of contemplated transactions.
Christian combines deep legal expertise in tax law with extensive commercial experience and a solid background in economics and finance. This unique combination enables him to provide precise advisory services across a broad spectrum of tax-related issues for enterprises of all sizes.
