Refund of withholding tax on interest, royalties and leasing payments
Companies that have had withholding tax deducted on interest, royalties and leasing income received from a Norwegian company or branch, can apply for a refund if they believe that too much tax has been deducted.
How to apply for a refund
Send the application to
Postboks 9200 Grønland
Starting in 2021, Norway has introduced withholding tax on interest, royalties or leasing payments from Norwegian companies to related entities in low tax countries. The Norwegian company making the payment is responsible for deducting the withholding tax.
The rate is usually 15 percent of the gross payment, but can be lower if the recipient is located in a country that has a tax treaty with Norway. If the company is located within the European Economic Area (EEA), it may be exempt from withholding tax.
The company can also apply for a refund if the basis for the deducted withholding tax is incorrect. For example:
- the Norwegian company making the payment has erroneously considered the payment as interest, royalties or leasing payments,
- the Norwegian company making the payment has erroneously considered the recipient as being domiciled in a low tax jurisdiction,
- the Norwegian company making the payment has erroneously considered the recipient a related entity,
- the recipient is a natural person not liable for withholding tax.
If you believe that your company is entitled to a reduced rate or that the withholding tax for other reasons is incorrect, you can apply for a refund of deducted withholding tax.
The deadline for applying for a refund is three years from the end of the year when the withholding tax is paid.
The application must include the following
- Name of the claimant
- Tax identification number (tax ID/TIN)
- Contact information
- Information about the payer (the company that has withheld tax):
- Name of the payer
- Tax identification number (Tax-ID/Org no.)
- If the application is filed through a Representative:
- Identification number
- Contact information
- The application must specify the type of payment on whivh withholding tax has been withheld (I.e., interest, royalty or leasing payments for ships, vessels, rigs, planes, helicopter)
- You must include an overview of all the payments, tax withheld and the total refund amount claimed
- If you apply under a tax treaty:
- A certificate of residence issued by the tax authorities in your country of residence, specifically confirming that you are resident in that country under the tax treaty with Norway. The certificate of residence must confirm that the applicant was resident under the relevant double taxation treaty with Norway for the year(s) the taxable payments where received.
- If you apply under the exemption for establishments within the EEA:
- A certificate of residence or certificate of registration issued by a public authority as confirmation that the applicant is registered and based within the EEA
- An explanation for why the applicant should be considered to carry out genuine economic activity within the EEA.
- Payment information:
- Name of the Bank
- IBAN or SWIFT/BIC number
- Name of the account holder
- Payment reference, in order for the recipient to identify the payment
- Other information including legal, organisational and tax related circumstances relevant to the application
All required documentation must be included in the application. Insufficient documentation or information results in longer processing time, and the application may be rejected or dismissed. Additional information may be relevant in order to show that the requirements for reduced withholding tax have been fulfilled.
The application must be signed by the claimant. If a representative submits the application, a signed power of attorney must be presented. You must also attach a certificate that confirms that the application and/or power of attorney is signed by a person authorised to sign on behalf of the applicant (like a certificate of registration).
If someone other than the applicant is to receive the refund payment, a power of attorney must confirm that the recipient is authorised to receive the refund payment.