Refunds of withholding tax on share dividends
As a foreign shareholder, you have limited tax liability to Norway for share dividends you've received from Norwegian companies. As a rule, the Norwegian company must deduct 25 percent withholding tax on share dividends. The tax rate may be lower due to tax treaties or Norwegian tax regulations.
If you're entitled to a lower tax rate than the rate deducted on your dividend payment, you can apply for a refund of too much paid withholding tax. Only shareholders who are final dividend recipients can claim a refund of withholding tax.
You may apply for a refund of withholding tax as soon as the company’s deadline for correction has passed.
The company assesses withholding tax by submitting a notification of withholding tax on share dividends. The company may submit a correction up to 3 months after submitting the notification of deduction, and until 31 December of the income year. This method lets the company correct errors in previously submitted notifications.
The correction deadline must have passed before you can apply for refund of withholding tax.
The application deadline is 5 years
The deadline for applying for a refund of withholding tax is five years. The deadline is calculated from the end of the income year when dividends were paid.
Send the application to
Postboks 9200 Grønland
If you have questions about refund of withholding tax on dividends, you may contact us by e-mail at [email protected]
- Tax identification number (tax ID / TIN)
- Total amount of refund claimed
- If you’ve received several dividends, you must include an overview of all dividends and the total amount of refund claimed per year
- If you’re a corporate shareholder, you must specify in the application if you apply for a refund under a tax treaty or the exemption method
- If you apply under a tax treaty:
- A certificate of residence issued by the tax authorities in your country of residence, confirming that you're a resident in that country under the tax treaty with Norway. The certificate of residence must be issued in the shareholder's name alone, and must be valid for the year when dividends were paid.
- If you apply under the exemption method:
- A certificate of residence or certificate of registration issued by a public authority as confirmation of the shareholder’s legal establishment within the EEA.
- A statement of the organisational structure, including an evaluation of which Norwegian entity the shareholder is comparable to in the Taxation Act section 2-38, subsection 1, letters a-h.
- Reasons for why the shareholder should be considered as genuinely established and to be carrying on genuine economic activity within an EEA member state, pursuant to the Taxation Act section 2-38, subsection 5.
- Credit advice (dividend receipt), showing that you’ve received dividends. The receipt must be issued by a bank and contain the following:
- the name of the final dividend recipient
- name and ISIN on the share
- number of shares and gross dividend per share in NOK
- pay-date, ex-date or record-date
- total gross amount and deducted withholding tax in NOK (it must state that withholding tax has been deducted, not just tax)
- If the dividend has gone through several transactions, the entire transaction chain must be documented.
- VPS account number and name of the account holder in the Norwegian Central Securities Depository (CSD) 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 name of the custodian holding the account
- If you do not have the VPS information, contact your custodian or the account operator to receive this information
- Payment information:
- The IBAN account must accept NOK since all refunds are transferred in NOK
- Name of account holder
- A Norwegian account number or IBAN and SWIFT/BIC code
- Payment reference of maximum 20 characters will simplify the payment
- Other relevant information, including legal, organisational and tax related circumstances
The application must be signed by the final dividend recipient. If a representative of the final dividend recipient submits the application, a signed power of attorney must be presented.
All required documentation must be enclosed with the application. Missing information in the application 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.
Possible basis for refund of withholding tax
- Tax treaty
If you’re a tax resident in a country with which Norway has entered into a tax treaty, the withholding tax rate is usually 15 percent. Rates according to different tax treaties are available at regjeringen.no/kildesatser. Some tax treaties have different requirements, but most treaties require that the shareholder is a tax resident in the contracting state and a beneficial owner of dividend.
- The shareholder model
If you’re a tax resident in the EEA and a final dividend recipient, the withholding tax may be reduced by deduction for risk-free return if the rate of withholding tax is higher than tax on dividends after risk-free return. Usually, it's impossible to receive a full refund of withholding tax by the shareholder model. Information stating that claims submitted according to the shareholder model always entitle you to a full refund of withholding tax is wrong. Read more about the shareholder model and deduction for risk-free return.
Please note that refunds under a tax treaty are usually more profitable than refunds under the shareholder model.
- Tax treaty
If the shareholder is a tax resident in a country with which Norway has entered into a tax treaty, the withholding tax rate may be less than 25 percent. Rates according to different tax treaties are available at regjeringen.no/kildesatser. Some tax treaties have different requirements, but most treaties require that the shareholder is a tax resident in the contracting state and a beneficial owner of dividend.
- Exemption method
Some corporate shareholders domiciled in the EEA may claim an exemption from withholding tax according to the exemption method. In order to claim a refund under the exemption method, the shareholder must be comparable to one of the Norwegian taxable entities listed under the Taxation Act section 2-38, subsection 1, letters a-h.
- Moreover, the shareholder must be genuinely established and carry on genuine economic activity in an EEA country. The shareholder must also be a final dividend recipient.
Do you want to avoid the refund process?
Foreign shareholders can avoid having to apply for refund of withholding tax. The correct withholding tax rate can be deducted immediately when dividend is paid if the shareholder has provided all necessary documentation.