Reduced withholding tax on future dividends for foreign shareholders
As a rule, Norwegian companies deduct 25 percent withholding tax on share dividends. However you may be entitled to a reduced withholding tax rate on dividends you receive. To get a reduced rate upon payment, you must provide documentation confirming that you or your company is entitled to it.
Does this apply to me?
The information on this page applies to you if you:
- are a foreign shareholder in a Norwegian company, or you represent a foreign shareholder
- expect to receive dividends from a Norwegian company
If you have already received the dividend, you must apply for a refund of withholding tax.
To be entitled to reduced withholding tax, you must:
- be tax resident in a country Norway has a tax treaty with
- not be tax resident in Norway
If you have previously been resident in Norway, you must have emigrated for tax purposes before you can claim a reduced withholding tax rate.
To be entitled to an exemption, the shareholder must:
- be equivalent to one of the Norwegian taxable entity as set out in section 2-38, subsection 1, letters a-h cf. letter i, of the Taxation Act. Foreign corporate entities where the owners have limited liability will normally fulfil this condition.
- be genuinely established and carry out real economic activity in an EEA country.
- be the final dividend recipient. If a shareholder, for example, is structured as an umbrella fund with multiple sub-funds, only the sub-funds are considered the final dividend recipients.
Check if your bank can deduct tax at a reduced rate
In the list below, you can find all banks that have been approved by the Tax Administration to deduct withholding tax at a lower rate than 25 percent.
In the list below, you can find all banks that have been approved by the Tax Administration to deduct withholding tax at a lower rate than 25 percent.
The list shows the name of the bank, the country where the bank's head office is located, and whether the bank has permission to deduct withholding tax at:
- 0 percent tax rate (exemption method) and/or
- reduced rate pursuant to a tax treaty
Note that the tax exemption method does not apply to personal shareholders (private individuals).
By clicking on the link in the bank's name, you'll be redirected to Finanstilsynet's (the Financial Supervisory Authority of Norway) website with information about the bank.
You can search for a bank or a country:
How to obtain relief at source
Personal shareholder
You must have the following documentation at hand:
- A self-declaration stating that you're the final dividend recipient (beneficial owner). There are no formal requirements for the declaration, but it must be signed and dated.
- If you're not the one signing the self-declaration, the person signing must provide a power of attorney from you.
- A certificate of residence from the tax authorities in your country of residence, which clearly states that you are a tax resident in that country under a tax treaty with Norway. The certificate of residence must not be older than three years at the time of the tax deduction.
If the certificate of residence is issued for a previous income year, it's valid from the end of the income year. If it specifies a period between two dates, it must be renewed within three years of the end date.
Example: A certificate of residence confirming residence from 31 August 2018 to 31 December 2018, must be renewed within 31 December 2021.
You do not have to provide a certificate of residence if you expect that the ordinary dividends for the whole year will amount to less than a total of NOK 10,000. The threshold amount applies per company you have invested in.
In the event of extraordinary dividend distributions (in addition to the ordinary dividends), a new threshold amount of NOK 10,000 in total will apply.
Exception from the documentation requirements
If the company distributing the dividend can confirm that you're entitled to a reduced withholding tax rate, you do not need to provide the documentation described above.
Do not send the documents to the Norwegian Tax Administration.
Who you must provide the documentation to depends, on whether the Norwegian company in which you own shares is listed on the Oslo Stock Exchange (Oslo Børs) or not.
If the company is listed on the Oslo Stock Exchange, the shares are registered in the Norwegian Central Securities Depository (VPS). The VPS account and the shares can be registered directly in the shareholder’s own name or in the name of the custodian.
- The shares are registered in the custodian’s name (NOM account): Present the documentation to the custodian.
- The shares and the account are registered directly in your own name: Present the documentation to the account operator. The account operator is the entity that has opened and administers your VPS account.
If you own shares in a company that is not listed on the Oslo Stock Exchange, you must present the documentation directly to the Norwegian company that distributes the dividend.
The documents can be kept electronically
The custodian, account operator, or the distributing company may store the documentation electronically. It’s not necessary to store them in paper form.
Corporate shareholder
The pre-approval confirms that you are entitled to reduced withholding tax deductions. You do not need to apply for pre-approval if you have already recieved a decision granting a refund of withholding tax and the legal basis is the same.
When you apply for pre-approval, you can apply under different legal bases:
A corporate shareholder may be entitled to a reduced withholding tax rate if the shareholder is domiciled in a country Norway has a tax treaty with.
Download and complete:
The application must include the following:
You must enclose a valid certificate of residence issued by the tax authorities in the shareholder’s country of residence. It must clearly state that the shareholder was a tax resident in that country pursuant to the tax treaty with Norway. The certificate of residence cannot be older than six months.
If you claim a refund of withholding tax under a special provision in the tax treaty, you must specify this in the application and attach documentation confirming that the shareholder meets the conditions in the relevant special provision.
Only corporate shareholders domiciled in the EEA may be granted exemption from withholding tax under the tax exemption method in section 2-38 of the Norwegian Taxation Act. To be entitled to an exemption, the shareholder must:
- be equivalent to a Norwegian taxable entity covered by the tax exemption method in the Taxation Act
- be genuinely established and carry out genuine economic activity within the EEA
- be the final dividend recipient
Download and complete:
The application must include the following:
- A certificate of residence or a registration certificate, showing that the shareholder is domiciled in an EEA country. The certificate must not be older than six months.
- 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, cf. 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.
Representatives applying on behalf of a shareholder must either
- provide a signed power of attorney from the shareholder, or
- the shareholder must sign the application form themselves.
Submit the application with required documentation to:
Skatteetaten
Postboks 9200 Grønland
0134 Oslo
You do not need to renew the pre-approval if the circumstances it is based upon are the same
- Change of organisational form
- Change of business address to another country
- Mergers and demergers, sale of shares and other transactions that change the legal structure and ownership of the company
- Changes in the entity's purpose or objectives as set out in the operating documents, for example, articles of association
- Change of the shareholder’s name
- Change of business address within the same country
You must have the following documentation:
- Pre-approval or a decision granting a refund of withholding tax from the Norwegian Tax Administration.
- The Luxembourg SICAV UCITS Part I is exempt from this requirement.
- Note: When the basis is the tax exemption method, you must provide a self-declaration confirming that the grounds on which the pre-approval or decision on refund of withholding tax is based remain unchanged. The self-declaration must not be older than three years at the time of the tax deduction.
- A confirmation from the shareholder that the shareholder is the final dividend recipient (beneficial owner).
- There's no requirement as to the form of the declaration, but it must be signed and dated.
- If you're not the one signing the self-declaration, the person signing must provide a power of attorney from you.
- Certificate of residence or registration certificate (EEA only) from the tax authorities in the shareholder’s country of residence.
- The certificate of residence or registration certificate must not be older than three years at the time of the tax deduction.
- If you require a reduced withholding tax rate under a tax treaty, the certificate of residence must clearly state that the shareholder was a tax resident in that country pursuant to the tax treaty with Norway.
If the certificate of residence is issued for a previous income year, it's valid from the end of the income year. If it specifies a period between two dates, it must be renewed within three years of the end date.
Example: A certificate of residence confirming residence from 31 August 2018 to 31 December 2018, must be renewed within 31 December 2021.
The general rule is that the certificate of residence must refer to the tax treaty with Norway. We accept certificates of residence without such referrals in exceptional cases based on an individual assessment.
We are familiar with American tax authorities (IRS) not issuing certificates of residence that refer to the tax treaty. Certificates of residence issued by the IRS are still accepted as sufficient proof of tax residency under the tax treaty between Norway and the USA.
Exception from the documentation requirements
If the company distributing the dividend can confirm that you're entitled to a reduced withholding tax rate, you do not need to provide the documentation described above.
Do not send the documents to the Norwegian Tax Administration.
Who you must provide the documentation to depends on whether the Norwegian company in which you own shares is listed on the Oslo Stock Exchange (Oslo Børs) or not.
If the company is listed on the Oslo Stock Exchange, the shares are registered in the Norwegian Central Securities Depository (VPS). The VPS account and the shares can be registered directly in the shareholder’s own name or in the name of the custodian.
- The shares are registered in the custodian’s name (NOM account): Present the documentation to the custodian.
- The shares and the account are registered directly in your own name: Present the documentation to the account operator. The account operator is the entity that has opened and administers your VPS account.
If you own shares in a company that is not listed on the Oslo Stock Exchange, you must present the documentation directly to the Norwegian company that distributes the dividend.
The documents can be kept electronically
The custodian, account operator, or the distributing company may store the documentation electronically. It’s not necessary to store them in paper form.
Specific information if you:
Some changes require a renewal of your pre-approval.
Circumstances that require a renewal of the pre-approval:
- Change of organisational form
- Change of business address to another country
- Mergers and demergers, sale of shares, and other transactions that change the legal structure and ownership of the company
- Changes in the entity's purpose or objectives as set out in the operating documents, for example, articles of association
Circumstances that do not require a renewal of the pre-approval:
- Change of the shareholder’s name. You must still present the confirmation of the name change for the custodian or account operator. The confirmation must be signed and dated.
- Change of business address within the same country
The general rule is that the certificate of residence must refer to the tax treaty with Norway. We accept certificates of residence without such referrals in exceptional cases based on an individual assessment.
We are familiar with American tax authorities (IRS) not issuing certificates of residence that refer to the tax treaty. Certificates of residence issued by the IRS are still accepted as sufficient proof of tax residency under the tax treaty between Norway and the USA.
The documentation requirements also apply to intergovernmental organisations.
As an alternative to a registration certificate or certificate of residence as documentation, intergovernmental organisations may provide a referral to a treaty explicitly stating that the organisation is exempt from tax in the member countries.
When you have global tax liability to Norway, you cannot claim a reduced withholding tax on dividends under this scheme.
If the company paying the dividend is unsure if you have a global tax liability to Norway or another country, you can request a certificate of residence from us to get confirmation that you have a global tax liability to Norway pursuant to Norwegian national law.
Contact us
If you have any questions, you can write to us.
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Relevant legislation
- Tax exemption for corporate shareholders: The Taxation Act, section 2-38
- The tax-deducting party’s access to change fixed amend the tax assessment on dividends to foreign shareholders: Tax Administration Regulation, section 9-5-1
- Dividends distributed to a shareholder domiciled abroad: The Taxation Act, section 10-13
- The Parliament's decision concerning taxes on income and wealth, etc.: The Norwegian Parliament's decision concerning taxes, section 3-5
- Documentation requirements for a reduced withholding tax rate on dividends to foreign shareholders:
The Tax Payment Regulations, section 5-10(a) (available in Norwegian only). The tax office's unofficial English translation.