Beneficial owners – Norway
The following types of beneficial owner are recognised for tax purposes in Norway:
Debt securities | |
Beneficial owner | Tax rate |
All (No withholding tax is deducted on interest from Norwegian debt securities held in Clearstream Banking) | 0% |
Equities | |
Beneficial owner | Tax Rate |
Non-resident of a DTT country | DTT |
Non-resident EEA entities qualifying for the tax-exemption method | 0% |
International organisations and foreign governments | 0% |
Exemption from withholding tax under the tax exemption method:
Only corporate shareholders domiciled in the EEA may be entitled to exemption from withholding tax 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 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 from withholding tax (zero percent tax rate) in connection with dividend payments.
For more information on reduced withholding tax on dividends please click here.