Norway

Norway imposes WHT on dividends paid to foreign shareholders. The internal WHT rate on dividends is 25%, which may either be reduced under the exemption rule or by an applicable tax treaty. To qualify for the exemption rule, the recipient of the dividends has to be a corporate investor resident in an EEA country and must also fulfil certain substance requirements.

Norway imposes a 15% WHT rate on the gross payment on interest, royalties, and certain payments for lease of tangible assets to related parties resident in low-tax jurisdictions. WHT will not be imposed when the related party recipient of the interest, royalty, or lease payments is tax resident in an EEA state and is actually established and carries out genuine business activities.

A tax treaty may also reduce or exempt WHT on the payment.

Dividends

Notes

1. 25% of the capital.
2. 30% of the capital and an investment of no less than 100,000 United States dollars (USD).
3. 10% of the capital.
4. 10% of the voting rights.
5. 25% of the voting rights.
6. 50% of the voting rights.
7. 5% for over 70% of the capital; 10% for 25% to 70% of the capital.
8. 15% of the capital.
9. 10% of the capital for an uninterrupted 24-month period.
10. 80% of voting rights for a 12-month period.
11. 20% of the capital provided that such dividends are exempt from tax in the other state.
12. 10% of the capital for an uninterrupted 12-month period.
13. WHT rate applies to certain pension funds.
14. WHT rate applies to certain governmental owned entities and bodies.
15. WHT rate applies to certain pension schemes.
16. The tax treaties with Barbados, Curacao, Jamaica, Sierra Leone, and Trinidad and Tobago were resolved to be terminated by royal resolution on 9 June 2023. Diplomatic notes have been sent to all these countries, and the terminations took effect on 1 January 2024.