Today, we submitted an AR filing (Shareholder Register Return) related to a highly complex group transaction involving multiple companies — including two listed companies, as well as several unlisted entities registered in our own shareholder management system.

In short, ownership in subsidiaries of a listed company was distributed through a return of capital, and subsequently merged into a sub-subsidiary with consideration in another listed company.

Complicated? Yes.

The result?

An AR submission involving well over 10,000 shareholders with continuity transactions.

It is difficult to say this with absolute certainty, but this is likely among the largest AR filings for an unlisted company ever submitted via Altinn to the Norwegian Tax Administration.

When theory meets practice in AR reporting

For many, the AR filing is something that “just needs to be submitted.”

In practice, anyone who has worked with:

  • shareholder registers

  • Shareholder Register Returns (AR)

  • Altinn reporting

  • AR controls by the Norwegian Tax Administration

  • VPS data and Euronext Securities Oslo

knows how quickly complexity arises — especially when:

  • multiple companies are involved within the same group

  • ownership is transferred internally

  • listed and unlisted structures are combined

  • transactions span multiple systems, registers, and jurisdictions

  • mergers and/or demergers are part of the transaction

In this case, data volume, accuracy, and traceability were absolutely critical.

Development, not just reporting

Delivering a correct AR filing at this scale required:

  • further development of our systems

  • handling extremely large shareholder datasets

  • validation of ownership, holdings, and transactions

  • structuring data in accordance with the Norwegian Tax Administration’s AR specifications — under the new standard

This is not manual work.

This is system and process engineering.

Close collaboration with all parties involved

A key success factor was strong dialogue and coordination across all stakeholders:

  • the Norwegian Tax Administration, for clarifications on reporting and format

  • legal advisors, for correct interpretation of the transaction structure

  • Euronext VPS, for coordination related to VPS-registered companies

  • the companies within the group, ensuring high-quality underlying data

AR reporting at this level is as much about coordination and understanding as it is about technology.

Why this matters

Errors in the AR filing can result in:

  • incorrect tax bases for shareholders

  • incorrect wealth valuations

  • discrepancies identified by the Tax Administration

  • time-consuming corrections after submission

  • fines and sanctions for non-compliance

When 10,000+ shareholders are involved, the margin for error is correspondingly small.

A reminder ahead of the next AR deadline

This submission is a clear reminder that:

  • the AR filing is not a mere formality

  • large and complex ownership structures require robust systems

  • early dialogue saves everyone time and effort

  • automation and data quality are absolutely essential

For us, this is a strong example of why shareholder administration, VPS account management, and AR reporting constitute a specialized discipline — not just an annual task on the calendar.