Refunds of withholding tax on dividends for foreign shareholders

If you’ve received dividends from a Norwegian company with a 25 percent withholding tax, and you fulfil the requirements for a lower withholding tax rate, you can apply for a refund. 

Does this apply to me?

The information on this page applies to you if you: 

  • are a foreign shareholder in a Norwegian company, or if you represent a foreign shareholder 
  • have received dividends on which too much withholding tax has been deducted 

If you have not recieved the dividends yet, and you are eligible for it, they may be subject to a reduced withholding tax rate. 

To be entitled to a refund of withholding tax, you must: 

If you have previously been resident in Norway, you must have emigrated for tax purposes before you can claim a reduced withholding tax rate. 

Please note: The Norwegian Tax Administration does not transfer payments of less than NOK 50,00, including interest.

The scheme cannot be used as proof of paid withholding tax.  

The Tax Administration cannot confirm how much withholding tax has been deducted and paid for each foreign shareholder. This is because we do not have information about each shareholder. 

If you want a deduction for Norwegian withholding tax in your home country, you must use supporting documents from your bank or your custodian. The dividend receipt, which shows how much tax has been deducted, serves as the supporting document. 

When you can apply for a refund

Norwegian companies that distribute dividends have access to correct the deducted withholding tax within three to four months following a dividend payment, and no later than 31 December in the year the dividend was paid. 

This correction deadline must have passed before you can apply for a refund of withholding tax. This usually means four months after the dividend payment. 

The application deadline is 5 years from the end of the year in which you received the dividend. 

Legal basis for the claim

You must choose a legal basis for your refund application. The documentation requirements depend on the legal basis for your claim.

Read about the different legal bases: 

Both personal shareholders and corporate shareholders may apply for a refund  pursuant to a tax treaty. 

This means that you may apply for a refund equal to the difference between deducted withholding tax (usually 25 percent) and the rate in the tax treaty. 

Example: 
Gross dividends: NOK 10,000 
Deducted withholding tax (25%): NOK 2,500 
The tax treaty entitles you to 15% tax (NOK 1,500) 
Your refund is NOK 1,000 

Check the overview of the tax treaties and the tax rates applicable for your country. 

Corporate shareholders domiciled in the EEA may claim an exemption from withholding tax (full refund) according to the tax exemption method in section 2-38 of the Norwegian Taxation Act. To fulfil the requirements under the tax exemption method, the company 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 

You can apply for reduced withholding tax for the risk-free return allowance when: 

  • you're tax resident within the EEA 
  • the risk-free return allowance will result in a lower withholding tax than a tax treaty would 

It's usually not possible to receive a full refund of withholding tax under the shareholder's model. A refund under a tax treaty is usually more beneficial. 

Documentation requirements

The documentation you must provide depends on the legal basis for your claim.

When you apply pursuant to a tax treaty, you must provide the following: 

  • Tax identification number (tax ID/TIN) from the country you were a tax resident in at the time of the dividend distribution (the country you're applying for a refund pursuant to the tax treaty with). 
  • Dividend receipt (credit advice) showing that you've received dividends and that withholding tax has been deducted. 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, you must provide proof of the entire transaction chain. 
  • VPS account number and name of the account holder in VPS, if the shares were registered in the Norwegian Central Securities Depository (VPS). 
    • 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. The custodian/account operator can choose to send the information directly to the Tax Administration. 
  • Payment information 
    • Name of account holder 
    • A Norwegian account number or IBAN and SWIFT/BIC code 
    • State a valid currency for payment. 
    • A payment reference of maximum 20 characters will simplify the payment. 
  • Certificate of residence from the tax authorities in your country of residence. 
    • It must clearly state that you were a tax resident in that country pursuant to the tax treaty with Norway at the time the dividends were paid. 
    • The certificate must be issued in the final dividend recipient’s name alone, and it must be valid for the year the dividend was distributed. 
  • Other relevant information, including legal, organisational and tax related circumstances.

Refunds pursuant to special provisions

The documentation requirements vary depending on which special provision the applicant bases their claim on.

Documentation confirming that a corporate shareholder meets the conditions in the relevant special provision could, for example, be documentation that verifies: 

  • the shareholder's ownership share in the Norwegian company, 
  • that the shareholder is a governmental entity,  
  • an agreement on exemption from withholding tax for tax-exempt institutions 

Only corporate shareholders domiciled in the EEA may apply under the tax exemption method. 

When you apply under the tax exemption method, you must provide the following: 

  • Tax identification number (tax ID/TIN) 
  • A statement of the shareholder’s organisational structure, including an assessment of which Norwegian taxable entity the shareholder is equivalent to as set out in section 2-38, subsection 1, letters a-h, see 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. 
  • Dividend receipt (credit advice) showing that the shareholder has received dividends and that withholding tax has been deducted. 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, you must provide proof of the entire transaction chain. 
  • VPS account number and name of the account holder in VPS, if the shares were registered in the Norwegian Central Securities Depository (VPS). 
    • 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. The custodian/account operator can choose to send the information directly to the Tax Administration. 
  • Payment information 
    • Name of account holder 
    • A Norwegian account number or IBAN and SWIFT/BIC code 
    • State a valid currency for payment. 
    • 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 was domiciled within the EEA at the time of dividend distribution. 
  • Other relevant information, including legal, organisational and tax related circumstances. 

Only personal shareholders domiciled in the EEA may apply under the shareholder's model. 

When you apply under the shareholder's model, you must provide the following : 

  • Your name and address. 
  • Tax identification number (tax ID/TIN) from your country of residence. 
  • The total amount you claim refunded. 
    • If you’ve received several dividends, you must include an overview of all dividends and the total amount of refund you're claiming. 
  • Certificate of residence from the tax authorities in your country of residence. The certificate must be issued in the final dividend recipient’s name alone, and it must be valid for the year the dividend was distributed. 
  • Proof of purchase, showing the declared acquisition value of the shares, 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 in which you received the dividend. 
  • Dividend receipt (credit advice) showing that you've received dividends and that withholding tax has been deducted. 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, you must provide proof of the entire transaction chain. 
  • VPS account number and name of the account holder in VPS, if the shares were registered in the Norwegian Central Securities Depository (VPS). 
    • If the shares were registered on a nominee account (NOM account), you must provide the account number and the name of the custodianholding the account. 
    • If you do not have the VPS account information, you must contact your custodianor the account operator for investor. The custodian/account operator can choose to send the information directly to the Tax Administration. 
  • Payment information 
    • Name of account holder 
    • A Norwegian account number or IBAN and SWIFT/BIC code 
    • State a valid currency for payment. 
    • A payment reference of maximum 20 characters will simplify the payment. 
  • Other relevant information, including legal, organisational and tax related circumstances. 

If you apply under the shareholder's model, you must submit the application on paper. 

Submit the application

You can apply online. You must create a new user the first time you sign in. Save your login information to be able to check the status of your application later. 

When you apply online, you'll: 

  • receive a receipt for the submitted application 
  • be able to have a digital dialogue regarding your case 
  • receive all letters and the decision from us digitally 
  • get an overview of your submitted and processed applications

If you apply under the shareholder's model, you must submit the application on paper. 

If you cannot use the online application form, you must submit the application by post. 

Download the correct application form: 

You must enclose all the required documentation 

Incomplete applications may be rejected or dismissed. In some cases, we may ask you for additional information. 

Submit the application and all required documentation to: 

Skatteetaten 
Postboks 9200 Grønland 
0134 Oslo 

We do not send a confirmation when you submit the application on paper. 

Case processing time

The case processing time is currently up to 2 years. 

Applications on paper have a longer processing time than online applications. 

For representatives

When you apply on behalf of a shareholder, you must provide the  documentation described above. In addition, you must enclose: 

  • a signed power of attorney confirming that you're representing the shareholder and have authority to submit the application on behalf of the shareholder 
  • your own tax identification number (tax ID/TIN) 
  • documentation verifying the tax identification number 

It's possible to submit applications for multiple shareholders at the same time (bulk). The file must be in the XML format according to the technical specifications.  

Specific information if you:

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.

If you have a global tax liability to Norway, but reside abroad, withholding tax on dividends may have been incorrectly deducted.  

If you have a global tax liability to Norway, and withholding tax has been deducted, you can apply for a reimbursement.

If the company paying the dividend is unsure if you're a tax resident in Norway or another country, you can request a certificate of tax residence from us to get confirmation that you are a tax resident in Norway pursuant to Norwegian domestic law. Norwegian domestic law. 

Contact us

If you have any questions about the application, you can write to us. Quote your reference number. 

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Applications that are sent to the email address will not be processed. 

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