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Dividend withholding tax in Norway
Eirik G Kristoffersen - Associate Lawyer9. June 2022 1 min read

Dividend withholding tax in Norway

Foreign shareholders may claim refund of Norwegian dividend withholding tax. Here is a quick 5 step guide on how.

1) Dividend withholding tax rates

Dividends paid by a Norwegian company to non-resident shareholders are as a starting point subject to a 25% withholding tax.

For both corporate and individual shareholders, the withholding tax rate may be reduced by a tax treaty between Norway and the home state of the shareholder. This rate is commonly reduced to 15 % and, in certain cases, completely abolished.

Further, dividends distributed by Norwegian companies to a corporate shareholder resident in an EU/EEA member state may be exempt from withholding tax. This exemption applies regardless of the ownership participation or holding period. A condition for the exemption is however that the EU/EEA resident corporate shareholders is the beneficial owner of the dividends and that it is really established and carries out genuine economic business activities in its home state.

2) The withholding obligation

It is the Norwegian dividend distributing company that is liable for applying the correct withholding tax. In order to safeguard against the potential liability, the company will commonly apply the maximum rate.

It is then up to the foreign shareholder to approach the Norwegian tax authorities.

Guide: These are the Norwegian Tax Return rules

Learn everything about Norwegian Tax Return rules. Download free guide.

3) The tax refund claim

>Whether the shareholder is entitled to a reduced tax rate and thus should claim a tax refund depends on facts and circumstances, particularly where the shareholder is a resident and the ownership participation.

The claim may cover refund for the last five years.

4) Pre-approved reduced rate

It is worth noticing that the tax authorities may grant corporate shareholders upfront relief from the dividend withholding tax. This pre-approval could entail either a reduced rate or a complete abolishing of the withholding tax.

5) Our services

Our lawyers will be happy to assess the feasibility of a refund of the dividend withholding tax. If relevant, we may claim refund or apply for upfront relief on your behalf.

Guide: These are the Norwegian Tax Return rules

Learn everything about Norwegian Tax Return rules. Download free guide.
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Eirik G Kristoffersen - Associate Lawyer

Eirik mainly works with international employment and particularly with tax liability for foreign companies, as well as personal taxation. He assists Norwegian and foreign companies with their obligations in Norway, including the necessary reports, tax returns and complaints for private individuals. Eirik worked as a tax adviser in the Norwegian Tax Administration from 2015-2018, and legal adviser in Compendia from 2018-2022, and came to Magnus Legal in April 2022.

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