Form descriptions – Relief at source – Norwegian equities
The following is a list of information regarding the various tax forms to be completed in order to benefit from relief at source of withholding tax on dividends from Norwegian dividends. The templates of the forms are available in our Tax forms to use section.
Approval letter from the Norwegian Tax Authorities
The approval letter should be provided to Clearstream Banking in the form of:
- A reclaim decision letter from the Norwegian Tax Authorities (NTA) – to be provided in the form of a decision letter issued by the NTA for a previous refund application; OR
- A pre-approval letter from the NTA.
Beneficial owners that are required to obtain a pre-approval letter from the NTA must apply for the letter directly from the NTA.
Both the reclaim decision letter and pre-approval letter must confirm the beneficial owner's eligibility for either a reduced tax rate or full tax exemption of withholding tax under a DTT, full tax exemption under the Norwegian Tax Exemption Model (Tax Act, Section 2-38 paragraph 1 litra I and paragraph 5) or full tax exemption according to a relevant multilateral convention or other legal grounds, as applicable.
How to request the pre-approval letter from the NTA
Clearstream Banking do not assist with obtaining the pre-approval letter.
To request the pre-approval letter from the NTA beneficial owners must provide the below documentation, depending on their status:
Entities qualifying for a reduced tax rate or tax exemption pursuant to a DTT
- Application – reduced withholding tax rate (double taxation treaty);
- Other supporting documentation, as requested by the NTA in the application form.
Foreign EEA entities qualifying for the Tax Exemption Model
- Application – withholding tax exemption (Norwegian tax exemption method); and
- Other supporting documentation, as requested by the NTA in the application form.
International organisations and foreign governments qualifying for tax exemption
There is no official application form to be used by international organisations and foreign governments, when applying for a pre-approval letter from the NTA.
Such entities may instead provide the following documentation:
- A free format application, in which they include a reference or copy of the multilateral conventions or legal grounds under which they would qualify for such tax exemption; and
- A certification/ identification, which proves that the applicant is the international organisation (supranational entity) or foreign government it is claiming to be;
- Other supporting documentation, which the applicant may deem relevant for the NTA.
All applications should therefore be submitted directly by the beneficial owner or its representative under power of attorney to the NTA at the below address:
Central Office – Foreign Tax Affairs
P.O. Box 8031
N-4068 Stavanger
How many are provided? | One per beneficial owner |
Who completes it? | Norwegian Tax Authorities |
How often is it provided? | Once (as long as the actual conditions on which the approval is based, remain unchanged) |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Copy. |
Attestation
The attestation must be provided in original and must fulfil the below requirements:
- Include the beneficial owner's full name;
- Confirm the beneficial owner's legal status, as an International organisation or foreign government qualifying for tax exemption;
- Not be older than three years at the time of the dividend payment.
How many are provided? | One per beneficial owner. |
Who completes it? | The beneficial owner's local authority or other authority, depending on the organisation/entity in question. |
How often is it provided? | Every three years General rule: Three years after the last confirmed date on the attestation, meaning the date of issuance plus three (3) years. Exception: When the attestation refers to a specific period dated back in time, then it will be valid as from the last day of the confirmed period plus three (3) years. |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original required. |
Beneficial owner certificate
The Beneficial owner certificate must be signed by the beneficial owner and is a confirmation from the dividend recipient that he is the final beneficial owner of the dividend (that is, not a conduit or other pass-through entity).
How many are provided? | One per beneficial owner. |
Who completes it? | Beneficial owner. |
How often is it provided? | Once (as long as the actual conditions on which the declaration is based remain unchanged). |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original required. |
Certificate of Residence
The Certificate of Residence (COR) must be provided in original and must fulfill the below requirements:
- Be issued by the beneficial owner’s local tax authority;
- Include the beneficial owner’s full name, full address and country of tax residence;
- Include the Tax Identification Number (TIN);
- Confirm that the beneficial owner is resident in accordance with the relevant DTT with Norway or within the EEA, as applicable;
- Confirm that the DTT eligibility requirements for tax exemption are met, if applicable, by specifying the relevant DTT article under which the beneficial owner qualifies for tax exemption (required when claiming 0% under DTT – for example eligible Dutch pension funds or UK pension schemes);
- Not be older than three years at the time of the dividend payment.
How many are provided? | One per beneficial owner. |
Who completes it? | Beneficial owner's tax authority. |
How often is it provided? | Every three years General rule: Three years after the last confirmed date on the COR, meaning the date of issuance plus three (3) years. |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original. |
Declaration of unchanged tax status for entities claiming tax exemption
The declaration must be signed by the beneficial owner (entities only) and is a confirmation from the dividend recipient that his eligibility for tax exemption has not changed since the Norwegian Tax Authorities (NTA) issued the approval letter.
Beneficial owners are furthermore required to indicate in the Declaration, the NTA’s reference number assigned to the Approval letter. Such reference is currently stated by the NTA in the letter under “Our reference”.
How many are provided? | One per beneficial owner. |
Who completes it? | Beneficial owner. |
How often is it provided? | Every three years (cannot be older than three years at the time of the dividend payment). |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original required. |
Declaration of unchanged tax status for Luxembourg SICAV organised as UCITS claiming tax exemption
The declaration must be signed by the beneficial owner and is a confirmation from the dividend recipient that his eligibility for tax exemption due to his tax status remains unchanged.
How many are provided? | One per beneficial owner. |
Who completes it? | Beneficial owner. |
How often is it provided? | Every three years (cannot be older than three years at the time of the dividend payment). |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original required. |
Per-payment instruction
If the Clearstream Banking client has multiple beneficial owners holding the Norwegian equites in the account (omnibus account), a per-payment instruction must be submitted for each payment.
The per-payment instruction must be provided for each tax rate and country of tax residence requested and include:
- Impacted Clearstream Banking account number;
- ISIN;
- Corporate ID;
- Total holding;
- Number of shares for which the reduced or exempt tax rate applies.
Additionally, the following formatting information is required in the per-payment instruction in the following sections:
Beneficial owner details | Xact via Swift (Sequence C: BENODET) | Xact Web Portal (Section: Beneficial owner details) |
Legal status:
| :70E::CETI | Narrative |
Full name | :95V::OWND | Party |
Address for tax purpose | :95V::OWND | Party |
Country of tax residence | :94C::DOMI | Country of domicile |
Tax ID number | :95S::ALTE//TXID | BO TIN |
For full formatting requirements of these instructions, clients should refer to the MT564 Corporate Action Notification, to the Xact via Swift User Guide, and Announcements C18050 and C21034.
How many are provided? | One for every Clearstream Banking account and for each tax rate and country of tax residence requested. |
Who completes it? | Client. |
How often is it provided? | Per dividend payment. |
When is it provided? | One business day after the record date of each dividend payment by 10:00 CET. |
Copy or original? | Via Xact via Swift or a CA Instruction in Xact Web Portal. |
One-Time Certificate for Norwegian Equities
The One-Time Certificate (OTC) must be completed by the Clearstream Banking client and remains valid until revoked.
- Part 1 of the OTC (Segregated account per beneficial owner) will serve as a standing instruction, provided all other required documentation has been submitted.
- Part 2 of the OTC (Omnibus account) will require clients to submit instructions per payment.
How many are provided? | One per Clearstream Banking account or specified set of Clearstream Banking accounts. |
Who completes it? | Client. |
How often is it provided? | Once. |
When is it provided? | Four business days prior to the record date of the first dividend payment, by 10:00 CET. |
Copy or original? | Original required. |