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Reduced withholding tax on share dividends for foreign shareholders
Generally, Norwegian companies deduct 25 percent withholding tax on share dividends. As a foreign shareholder, you may be entitled to a lower withholding tax rate for dividend payments you receive.
Does this apply to me?
Specific information if you’re a foreign shareholder in a Norwegian company, or if you represent foreign shareholders.
To apply for reduced withholding tax on dividends, you cannot be tax resident in Norway. If you have previously been a tax resident in Norway, you must have emigrated for tax purposes before you can apply.
Two ways to obtain a lower withholding tax rate
Your bank deducts the correct withholding tax upon the dividend payment
Your bank applies the correct withholding tax rate immediately when the dividend is paid to you. This way, you do not have to actively do anything yourself.
Your bank can ensure that a lower tax rate is applied at the time of dividend payment. This way you avoid applying for a refund from the Norwegian Tax Administration.
Banks that are approved to apply the correct tax rate
The list below shows all banks that has been approved by the Norwegian Tax Administration to apply a lower withholding tax rate than 25 percent.
The list shows the bank's name, the country of the bank's headquarters, and whether the bank is authorized to apply withholding tax at
- 0 percent tax rate (exemption method) and/or
- reduced rate according to a tax treaty
Note that the exemption method does not apply to personal shareholders (private individuals).
To see more information about the bank, click on the banks name. This will redirect you to the Financial Supervisory Authority's page of the bank.
You apply for a refund after the dividend payment
If your bank does not apply the correct tax rate on the dividend payment, you can claim a refund afterwards.
Please note that the case processing time for refund applications is up to 2 years. We therefore recommend you contact your bank and check if you can get the correct tax deduction on future dividend payments.
How to apply
Personal shareholder
When you apply for a refund, you must know which agreements your country of residence has with Norway. You may be entitled to a refund on the basis of a tax treaty or Norwegian tax rules.
Refund under a tax treaty
You may be entitled to reduced withholding tax if you’re resident for tax purposes in a country with which Norway has a tax treaty. Some tax treaties have different conditions, but most treaties require that you (the shareholder) are resident in the country according to the conditions in the treaty, and that you’re the final recipient of the dividend (beneficial owner).
The withholding tax rate under a tax treaty is generally 15 percent. Check the overview of the tax treaties and the applicable tax rates to find out which tax rate applies to your country. You’ll find the rate for your country of residence under the column “Ordinary rates”.
Example
- You have received dividend of NOK 10,000
- The company has deducted 25 percent withholding tax on the dividend
- The tax treaty rate in your country is 15 percent — meaning 15 percent of the gross dividend is taxable to Norway
You can claim a refund of the difference between the deducted withholding tax and the taxable amount — 10 percent of the gross dividend:
|
Gross dividend |
Deducted withholding tax |
Treaty rate / taxable amount |
|
10,000 |
10,000 x 25 % |
10,000 x 15 % |
|
Refund claim |
|
10,000 x 10 % |
Refund under the shareholder model (deductible risk-free return)
If you’re a tax resident in the EEA and the final dividend recipient, the withholding tax may be reduced by a deduction for risk-free return. This only applies if the withholding tax, meaning the share of tax that the company has deducted on the dividend payment, is higher than the tax on the dividend after risk-free return is deducted.
Usually, it’s not possible to receive a full refund of withholding tax under the shareholder model, and refunds under a tax treaty are often more favourable.
Find your deductible risk-free return
Read more about tax rules (risk-free rules) for gains/losses from realisations and share dividends
The supporting documents you must provide depend on whether you:
- expect to receive or have received dividends
- you apply under a tax treaty or the shareholder model.
Certificate of residence
To prove that you’re entitled to a reduced tax rate, you must provide a certificate of residence issued by the tax authorities in your country of residence. The certificate must specifically confirm that you’re resident for tax purposes there in accordance with the tax treaty with Norway. The certificate must not be older than three years at the time of the tax deduction.
The certificate of residence is valid for three years. If the certificate is issued for an earlier income year, it's valid from the end of the income year. If the certificate specifies a time period between two dates, it must be renewed within three years from the end date.
Example 1: A certificate of residence issued for the 2018 income year, dated 1 November 2018, must be renewed within 1 November 2021.
Example 2: If a certificate of residence is issued for the 2015 income year, dated 1 November 2017, the three-year deadline will apply from 31 November 2015. The certificate must be renewed within 1 January 2019.
Example 3: A certificate of residence that confirms residence from 31 august 2018 to 31 December 2018, must be renewed within 31 December 2021.
You do not need to provide a certificate of residence if:
- you expect to receive ordinary dividends amounting to less than NOK 10,000 in total from one company in one year.
- the company pays dividend quarterly (four times a year) and none of the dividends are more than NOK 2,500.
- the company pays dividend each half-year (two times a year) and none of the dividends are more than NOK 5,000.
These amount limits apply per company you’ve invested in, which means there’s an amount limit of NOK 10,000 per distributing company.
In the event of extraordinary dividend distributions, meaning dividends that are paid in addition to the ordinary dividends in a year, a new amount limit of NOK 10,000 in total will apply.
A self-declaration that you’re the final dividend recipient
You must provide a signed self-declaration that proves you’re the final dividend recipient (beneficial owner). There’s no requirement as to the form of the declaration, but it must be signed and dated.
Provide the documentation before dividend is paid
The documentation must be provided before the tax deduction is carried out. This normally means before the dividend is distributed.
You must not provide the documentation to the Norwegian Tax Administration. Who you must provide the documentation to depends, amongst other things, on whether the Norwegian company you invest in is listed on the Oslo Stock Exchange (Oslo Børs). Most Norwegian public limited companies (allmennakseselskap) are listed on the Oslo Stock Exchange and have their own ISIN code. The ISIN code consists of 12 characters and starts with the country code “NO”.
If the distributing company is listed
If the distributing company is listed on the Oslo Stock Exchange, the shares are registered in a VPS account. The VPS account and the shares can be registered directly in the shareholder’s own name or in the name of the foreign custodian.
- If the shares are registered in the foreign custodian’s name (NOM account): Shareholders that own shares registered in a VPS account in the name of their foreign custodian, must provide the documentation to their custodian.
- If the shares and the account is registered directly in the shareholder’s own name: Shareholders that own shares registered in a VPS account directly in their own name, must provide the documentation to the account operator for investor. The account operator for investor is the one who has established and administers the VPS account.
If the distributing company is not listed
If you own shares in a company that is not listed on the Oslo Stock Exchange, you must provide the documentation directly to the Norwegian company that distributes the dividend.
Exception from the documentation requirementsThe shareholder does not have to provide the documentation if the distributing company has an overview of the shareholder’s identity and tax status and is therefore able to confirm that the shareholder is entitled to a reduced withholding tax rate at source.
Please note: If the company misjudges the shareholder's identity and tax status, the company can be held liable for incorrect withholding tax deductions. The company will not be held liable if the shareholder meets the documentation requirements.
The documentation can be kept electronically
The custodian or account operator can keep the documentation electronically. It is not necessary to store the documentation in paper form.
There are different alternatives and requirements for supporting documents depending on whether you’re applying for a refund pursuant to a tax treaty or under the shareholder model (risk-free return allowance).
If you apply under a tax treaty, you must prepare the following:
- A tax identification number (tax ID / TIN) from your country of residence. If you do not have this, you may use an alternative ID number (an ID number from your country of residence or passport number).
- Receipt of dividends (credit advice) showing that you’ve received dividend and that the dividend has been subject to withholding tax. The receipt must be issued by a bank and contain the following information:
- the name of the final dividend recipient (beneficial owner)
- the name and ISIN of the share
- the number of shares and gross dividend per share in NOK
- payment date, ex date or record date
- the total gross amount and deducted withholding tax in NOK (it must state that the dividend has been subject to withholding tax, not just tax)
- If the dividend from the company has gone through several transactions, the entire transaction chain must be documented
- If the shares were registered in the Norwegian Central Securities Depository (VPS), you must provide the VPS account number and the name of the account holder to which the shares were registered when dividend was paid.
- If the shares were registered on a nominee account (NOM account), you must provide the account number and the name of the custodian holding the account
- If you do not have the VPS account information, contact your custodian or the account operator for investor to receive the information
- Payment information:
- The name of the account holder and tax identification number (TIN)
- A Norwegian account number or IBAN and SWIFT/BIC code
- If the account does not accept NOK, you must specify a valid payment currency
- A payment reference of maximum 20 characters will simplify the payment
- A certificate of residence issued by the tax authorities in your country of residence, confirming that you’re resident for tax purposes in that country under the tax treaty with Norway. The certificate must be issued in the final dividend recipient’s name alone and must be valid for the year the dividend was paid.
- Other relevant information, including legal, organisational and tax-related circumstances
If you apply under the shareholder model (deductible risk-free return), you must submit the application on paper.
The application must include the following:
- Name and address
- A tax identification number (tax ID / TIN) from your country of residence. If you do not have this, you may use an alternative ID number (an ID number from your country of residence or passport number).
- The total amount of refund to be claimed
- If you’ve received several dividends, you must include an overview of all the dividends and the total amount of refund to be claimed per year
- A certificate of residence issued by the tax authorities in your country of residence, confirming that you’re resident for tax purposes within the EEA. The certificate must be issued in the final dividend recipient’s name alone, and it must be valid for the year the dividend was paid
- Proof of purchase, showing the declared acquisition value, the date you bought the shares, and the number of shares
- A confirmation that you’re the real owner of the shares per 31 December of the income year
- Receipt of dividends (credit advice) showing that you’ve received dividend and that the dividend has been subject to withholding tax. The receipt must be issued by a bank and contain the following information:
- the name of the final dividend recipient (beneficial owner)
- the name and ISIN on the share
- the number of shares and gross dividend per share in NOK
- payment date, ex date or record date
- the total gross amount and deducted withholding tax in NOK (it must state that the dividend has been subject to withholding tax, not just tax)
- If the dividend from the company has gone through several transactions, the entire transaction chain must be documented
- If the shares were registered in the Norwegian Central Securities Depository (VPS), you must provide the VPS account number and the name of the account holder to which the shares were registered when dividend was paid.
- If the shares were registered on a nominee account (NOM account), you must provide the account number and the name of the custodian holding the account
- If you do not have the VPS account information, contact your custodian or the account operator for investor to receive the information
- Payment information:
- Name of account holder
- A Norwegian account number or IBAN and SWIFT/BIC code
- If the account does not accept NOK, you must specify a valid payment currency
- Payment reference of maximum 20 characters will simplify the payment
- Other relevant information, including legal, organisational and tax-related circumstances
You can apply digitally. The first time you log in you will create a user account, with your choice of password and email address. Remember to save your login credentials to ensure you are able to log in to check your application status.
Processing time
Due to a large number of received refund applications, the case processing time is currently up to 2 years.
The processing time may vary depending on the number of applications we receive at any given time, the need for verifying documentation and the collection of any additional information.
Corporate shareholder
When you’re applying for a refund for a corporate shareholder, you must choose under which legal basis you apply. Corporate shareholders may be entitled to a reduced or zero percent withholding tax rate according to a tax treaty or exemption from withholding tax under the exemption method in section 2-38 of the Norwegian Taxation Act.
Refund under a tax treaty
Corporate shareholders may be entitled to reduced withholding tax if they’re domiciled for tax purposes in a country with which Norway has a tax treaty. Some tax treaties have different conditions, but most treaties require that the shareholder is domiciled in the country according to the conditions in the treaty, and that the shareholder is the final dividend recipient (beneficial owner).
The withholding tax rate under a tax treaty is generally 15 percent. Check the overview of the tax treaties and the applicable tax rates to find out which tax rate applies to your country.
Example
- You have received dividend of NOK 10,000
- The company has deducted 25 percent withholding tax on the dividend
- The tax treaty rate in your country is 15 percent — meaning 15 percent of the gross dividend is taxable to Norway
You can claim a refund of the difference between the deducted withholding tax and the taxable amount — 10 percent of the gross dividend:
|
Gross dividend |
Deducted withholding tax |
Treaty rate / taxable amount |
|
10,000 |
10,000 x 25 % |
10,000 x 15 % |
|
Refund claim |
|
10,000 x 10 % |
Refund under the exemption method
Some corporate shareholders domiciled in the EEA may be entitled to exemption from withholding tax (full refund) under the exemption method. The shareholder must fulfil the following conditions:
- The shareholder must be equivalent to a Norwegian entity type. The shareholder must be equivalent to one of the Norwegian taxable entities listed in section 2-38, subsection 1, letters a-h, letter i of the Taxation Act. Foreign corporate entities where the owners have limited liability will normally fulfil this condition.
- The shareholder must be genuinely established and carry out genuine economic activity. The shareholder must be genuinely established and carry out genuine economic activity in an EEA country. It’s important that the corporate shareholder carries out genuine economic activity in the relevant country and is not established there mainly due to tax benefits.
- The shareholder must be the final dividend recipient. Only the final dividend recipient may be entitled to exemption and full refund of withholding tax on dividend. For example, if the shareholder is structured as an umbrella fund with multiple sub-funds, only the sub-funds are considered the final dividend recipients.
When you as a company shareholder submit an application for reduced withholding tax, you may include a pre-approval. The pre-approval confirms that you’re entitled to reduced withholding tax.
Download and complete the form:
- Application – reduced withholding tax rate under a double taxation treaty
- Application – withholding tax exemption
Remember to enclose all the required supporting documents. Please note that we may request additional information to show that the conditions for reduced withholding tax are fulfilled.
Send the application to
Skatteetaten
Postboks 9200 Grønland
0134 OSLO
Your application will be processed within 8 weeks
We’ll reply to your application within 8 weeks from receiving it. We’ll send the reply by post to the sender of the application or to the address specified in the application.
A pre-approval is valid if the circumstances under which the approval is based have not changed. The same applies where a decision letter on approved refund is used as proof to be placed on an account with reduced withholding tax.
A pre-approval is valid if the circumstances under which the approval is based have not changed. The same applies where a decision letter on approved refund is used as proof to be placed on an account with reduced withholding tax.
The supporting documents you must provide depend on whether you:
- expect to receive or have received dividends
- you apply under a tax treaty or the exemption method.
- A tax identification number (tax ID/TIN) from the shareholder’s country of residence. If the shareholder does not have a tax ID, an alternative ID number can be provided. This may be an ID number from the shareholder’s country of residence, a LEI number (Legal Entity Identifier) or a EUID (European Unique Identifier).
- Receipt of dividends (credit advice) showing that the shareholder has received dividend and that the dividend has been subject to withholding tax. The receipt must be issued by a bank and contain the following information:
- the name of the final dividend recipient
- the name and ISIN of the share
- the number of shares and gross dividend per share in NOK
- payment date, ex date or record date
- the total gross amount and deducted withholding tax in NOK (it must state that the dividend has been subject to withholding tax, not just tax)
- If the dividend from the company has gone through several transactions, the entire transaction chain must be documented.
- If the shares are registered in the Norwegian Central Securities Depository (VPS), you must provide the VPS account number and the name of the account holder to which the shares were registered when dividend was paid.
- If the shares were registered on a nominee account (NOM account), you must provide the account number and the name of the custodian holding the account
- If you do not have the VPS account information, you must contact your custodian or the account operator for investor to receive the information
- Payment information:
- The name of the account holder and tax identification number (TIN)
- A Norwegian account number or IBAN and SWIFT/BIC code
- If the account does not accept NOK, you must specify a valid payment currency
- A payment reference of maximum 20 characters will simplify the payment
- A certificate of residence issued by the tax authorities in the shareholder’s country of residence, confirming the shareholder is domiciled for tax purposes in that country under the tax treaty with Norway. The certificate must be issued in the final dividend recipient’s name alone and must be valid for the year the dividend was paid.
- Other relevant information, including legal, organisational and tax-related circumstances
- A tax identification number (tax ID/TIN) from the shareholder’s country of residence. If the shareholder does not have a tax ID, an alternative ID number can be provided. This may be an ID number from the shareholder’s country of residence, a LEI number (Legal Entity Identifier) or a EUID (European Unique Identifier).
- A statement of the shareholder’s organisational structure, including an evaluation of which Norwegian taxable entity the shareholder is equivalent to as set out in section 2-38, subsection 1, letters a-h, letter i of the Taxation Act.
- Grounds for why the shareholder should be considered as genuinely established and carrying out genuine economic activity within the EEA, in accordance with section 2-38, subsection 5 of the Taxation Act.
- Receipt of dividends (credit advice) showing that the shareholder has received dividend and that the dividend has been subject to withholding tax. The receipt must be issued by a bank and contain the following information:
- the name of the final dividend recipient
- the name and ISIN on the share
- the number of shares and gross dividend per share in NOK
- payment date, ex date or record date
- the total gross amount and deducted withholding tax in NOK (it must state that the dividend has been subject to withholding tax, not just tax)
- If the dividend from the company has gone through several transactions, the entire transaction chain must be documented.
- If the shares are registered in the Norwegian Central Securities Depository (VPS), you must provide the VPS account number and the name of the account holder to which the shares were registered when dividend was paid.
- If the shares were registered on a nominee account (NOM account), you must provide the account number and the name of the custodian holding the account
- If you do not have the VPS account information, you must contact your custodian or the account operator for investor to receive the information
- Payment information:
- The name of the account holder and tax identification number (TIN)
- A Norwegian account number or IBAN and SWIFT/BIC code
- If the account does not accept NOK, you must specify a valid payment currency
- A payment reference of maximum 20 characters will simplify the payment
- A certificate of residence or certificate of registration issued by a public authority showing that the shareholder is domiciled within the EEA.
- Other relevant information, including legal, organisational and tax-related circumstances.
Provide the documentation before dividend is paid
The documentation must be provided before the tax deduction is carried out. This normally means before the dividend is distributed.
You must not provide the documentation to the Norwegian Tax Administration. Who you must provide the documentation to depends, amongst other things, on whether the Norwegian company you invest in is listed on the Oslo Stock Exchange (Oslo Børs). Most Norwegian public limited companies (allmennakseselskap) are listed on the Oslo Stock Exchange and have their own ISIN code. The ISIN code consists of 12 characters and starts with the country code “NO”.
If the distributing company is listed
If the distributing company is listed on the Oslo Stock Exchange, the shares are registered in a VPS account. The VPS account and the shares can be registered directly in the shareholder’s own name or in the name of the foreign custodian.
- If the shares are registered in the foreign custodian’s name (NOM account): Shareholders that own shares registered in a VPS account in the name of their foreign custodian, must provide the documentation to their custodian.
- If the shares and the account is registered directly in the shareholder’s own name: Shareholders that own shares registered in a VPS account directly in their own name, must provide the documentation to the account operator for investor. The account operator for investor is the one who has established and administers the VPS account.
If the distributing company is not listed
If you own shares in a company that is not listed on the Oslo Stock Exchange, you must provide the documentation directly to the Norwegian company that distributes the dividend.
Exception from the documentation requirementsThe shareholder does not have to provide the documentation if the distributing company has an overview of the shareholder’s identity and tax status and is therefore able to confirm that the shareholder is entitled to a reduced withholding tax rate at source.
Please note: If the company misjudges the shareholder's identity and tax status, the company can be held liable for incorrect withholding tax deductions. The company will not be held liable if the shareholder meets the documentation requirements.
The documentation can be kept electronically
The custodian or account operator can keep the documentation electronically. It is not necessary to store the documentation in paper form.
You can apply digitally. The first time you log in you will create a user account, with your choice of password and email address. Remember to save your login credentials to ensure you are able to log in to check your application status.
Processing time
Due to a large number of received refund applications, the case processing time is currently up to 2 years.
The processing time may vary depending on the number of applications we receive at any given time, the need for verifying documentation and the collection of any additional information.
Representatives
If you’re a representative submitting the application on behalf of the shareholder, you must submit
- a signed power of attorney, confirming that you represent the shareholder and that you’re authorised to apply on the shareholder’s behalf.
- Tax identification number (TIN) of the representative submitting the application
You can submit applications on behalf of several shareholder at the same time (bulk).
Contact us
If you have any questions concerning the application, you can contact us at int@skatteetaten.no. Remember to quote your reference number.
Applications that are sent to the email address, will not be processed.