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Unless otherwise indicated, the rates and thresholds stated in the chapter are applicable as of 1 January 2022.
A. At a glance
Corporate Income Tax Rate (%) 22 (a)
Capital Gains Tax Rate (%) 22 (a)
Branch Tax Rate (%) 22 (a)
Withholding Tax (%)
Dividends 25 (b)
Interest 0/15 (c)
Royalties from Patents, Know-how, etc. 0/15 (c)
Certain Lease Payments 0/15 (c)
Branch Remittance Tax 0
Net Operating Losses (Years)
Carryback 0 (d)
Carryforward Unlimited
(a) A 25% rate applies to companies in the financial sector (see Section B). (b) This tax applies to dividends paid to nonresident shareholders. Dividends paid to corporate shareholders that are tax residents and genuinely estab lished in member states of the European Economic Area (EEA) (including the European Union [EU], Iceland and Liechtenstein) are exempt from with holding tax.
(c) A 15% withholding tax on interest, royalties and certain lease payments to related entities resident in a low-tax jurisdiction has been introduced. The rules entered into force on 1 July 2021 for interest and royalties and on 1 October 2021 for certain lease payments. The withholding tax may be reduced or exempt under the provisions of a tax treaty entered into by Norway or when the recipient is a company that is actually established and carrying on genuine economic activities within the EEA. For the purpose of the rules, a company is considered a “related party” if the payer and the recipient are directly or indirectly under the same ownership and control by at least 50%. The term “low-tax jurisdiction” is to be interpreted in line with the controlled foreign company rules (see Section E).
(d) See Section C.
B. Taxes on corporate income and gains
Corporate income tax. In general, resident companies are subject to corporate income tax on worldwide income. However, profits and losses on upstream petroleum activities in other jurisdictions are exempt from Norwegian taxation. Nonresident companies are subject to corporate income tax on income attributable to Norwegian business operations.
A company is tax resident in Norway if it is legally incorporated according to Norwegian corporate law or if its effective management is carried out in Norway.
Rates of corporate tax. The corporate tax rate is currently 22%.
In addition to the general income tax of 22%, a special petroleum tax of 56% applies to income from oil and gas production and from pipeline transportation. A special power production tax of 37% applies on top of the general income tax of 22% for the generation of hydroelectric power.
For companies in the financial sector, a 25% rate applies if they are within the scope of the financial tax rules (see Financial tax).
Qualifying shipping companies may elect to be taxed under the Norwegian tonnage tax regime instead of the ordinary tax
regime. Under the tonnage tax regime, profits derived from qualifying shipping activities are exempt from income tax. However, companies electing the shipping tax regime must pay an insignificant tonnage excise tax. Financial income derived by shipping companies is taxed at a rate of 22%. Breach of the requirements under the regime generally leads to forced exit from the regime. The Norwegian Ministry of Finance submitted a pro posal for certain amendments to the tonnage tax regime for public consultation in September 2021. The most significant change is the proposal to introduce so-called “mixed use,” pro viding that certain types of activities (“additional activities”) that currently are not permitted will be allowed within the regime. The proposal is not intended to expand the types of income qualifying for tax exemption under the regime, but rather to increase the flexibility and reduce the risk of forced exit from the regime. If enacted, the defined additional activities will be subject to ordinary tax at a rate of 22%. In addition, certain other changes have been proposed. It is expected that the changes will be enacted during 2022.
Financial tax. A financial tax for companies in the financial sector was introduced from 1 January 2017. The main purpose of the financial tax is to serve as a form of substitute tax for financial businesses that are value-added tax (VAT)-exempt (that is, they benefit from the Norwegian VAT exemption for the sale and mediation of financial services). The financial tax consists of the following two elements:
• The application of a 25% rate on the income of companies covered by the financial tax, instead of the 22% rate, which applies to companies in all other sectors
• A 5% tax on wage costs
The main rule is that all companies that conduct activities that are covered by Group K “Financial and insurance activities” (Codes 64-66) in SN2007 (the European system NACE rev. 2) are subject to the financial tax. These types of activities are referred to as financial activities. The financial tax applies only to companies with employees.
The following businesses are typically subject to the financial tax:
• Businesses engaged in banking
• Businesses engaged in insurance (both life and general insur ance)
• Securities funds
• Investment companies
• Holding companies
• Pension funds
• Businesses performing services related to finance business, including administration of financial markets and mediation of securities
The 5% tax on wage cost is calculated based on the yearly pay ments to all of the company’s employees who perform financial activities as defined in Group K in SN2007. The same base ap plicable to the calculation of the employer’s social insurance con tribution is used for the calculation of the 5% tax on wage costs.
The following exemptions apply:
• An entity that has less than 30% of its total payroll cost relating to financial activities is exempt from the 5% part of the finan cial tax.
• An entity that has more than 70% of its total payroll cost relat ing to VAT-liable financial activities is exempt from the 5% part of the financial tax.
All companies covered by the financial tax can deduct the 5% financial tax on wage cost in calculating their taxable income for corporate income tax purposes.
Capital gains. In general, capital gains derived from the disposal of business assets and shares are subject to normal corporate taxes. However, for corporate shareholders, capital gains derived from the sale of shares in limited liability companies, partnerships and certain other enterprises that are qualifying companies under the tax exemption system are exempt from tax. This tax exemp tion applies regardless of whether the exempted capital gain is derived from a Norwegian or a qualifying non-Norwegian com pany. In general, life insurance companies and pension funds are not covered by the tax exemption regime.
For shares in companies resident in another EEA member state (the EEA includes the EU, Iceland, Liechtenstein and Norway), the exemption applies regardless of the ownership participation or holding period. However, if the EEA country is regarded as a low-tax jurisdiction (as defined in the Norwegian tax law regarding controlled foreign companies [CFCs]; see Section E), a condition for the exemption is that the EEA resident company be actually established and carrying out genuine economic activities in its home country.
For shares in non-EEA resident companies, the exemption does not apply to capital gains on the alienation of shares in the following companies:
• Companies resident in low-tax jurisdictions, as defined in the Norwegian tax law regarding CFCs; see Section E)
• Companies of which the corporate shareholder has not held at least 10% of the capital and the votes in the company for more than two years preceding the alienation
The right of companies to deduct capital losses on shares is basi cally eliminated to the same extent that a gain would be exempt from tax.
The exit from Norwegian tax jurisdiction of goods, merchandise, intellectual property, business assets and other items triggers capital gains taxation as if such items were sold at the fair market price on the day before the day of exit. The payment of the exit tax on business assets, financial assets (shares) and liabilities may be deferred if the taxpayer remains tax resident within the EEA. However, the deferred tax must be paid in equal installments over a period of seven years, calculated from the year of exit. Interest is calculated on the deferred tax amount. If a genuine risk of nonpayment of the deferred tax exists, the taxpayer must furnish security or a guarantee for the outstanding tax payable. No defer ral of the tax is available for intangible assets and inventory.
Administration. The annual tax return is due on 31 May for ac counting years ending in the preceding calendar year and must be submitted electronically. Assessments are made in the year in which the return is submitted (not later than 1 December). Tax is paid in three installments. The first two are paid on 15 February and 15 April in the year after the income year, respectively, each based on ½ of the tax due from the previous assessment. The last installment represents the difference between the tax paid and the tax due, and is payable three weeks after the issuance of the assessment. Interest is charged on residual tax.
Dividends. An exemption regime with respect to dividends on shares is available to Norwegian companies if the distribution is not deductible for tax purposes at the level of the distributing entity. However, the 100% tax exemption is limited to 97% if the recipient of the dividends does not hold more than 90% of the shares in the distributing company and a corresponding part of the votes that may be given at the general meeting (that is, the companies do not constitute a tax group of companies). In such cases, the remaining 3% of the dividends is subject to 22% taxa tion, which results in an effective tax rate of 0.66%.
The tax exemption applies regardless of the ownership participa tion or holding period if the payer of the dividends is a resident in an EEA member state. However, if the EEA country is regard ed as a low-tax jurisdiction, the EEA resident company needs to qualify as actually established and carrying out genuine eco nomic activities in its home country.
For non-EEA resident companies, the exemption does not apply to dividends paid by the following companies:
• Companies resident in low-tax jurisdictions as defined in the Norwegian tax law regarding CFCs (see Section E)
• Other companies of which the recipient of the dividends has not held at least 10% of the capital and the votes of the payer for a period of more than two years that includes the distribution date
Dividends paid to nonresident shareholders are subject to a 25% withholding tax. The withholding tax rate may be reduced by tax treaties. Dividends distributed by Norwegian companies to corpo rate shareholders resident in EEA member states are exempt from withholding tax. This exemption applies regardless of the owner ship participation or holding period. However, a condition for the exemption is that the EEA resident company be actually estab lished and carrying out genuine economic activities in its home country.
Foreign tax relief. A tax credit is allowed for foreign tax paid by Norwegian companies, but it is limited to the proportion of the Norwegian tax that is levied on foreign-source income. Separate limitations must be calculated according to the Norwegian tax treatment of the following two different categories of foreignsource income:
• Income derived from low-tax jurisdictions and income taxable under the CFC rules
• Other foreign-source income
For dividend income taxable in Norway (that is, dividends that are not tax-exempt under the exemption regime), Norwegian
companies holding at least 10% of the share capital and the voting rights of a foreign company for a period of more than two years that includes the distribution date may also claim a tax credit for the underlying foreign corporate tax paid by the foreign company, provided the Norwegian company includes an amount equal to the tax credit in taxable income. In addition, the credit is also avail able for tax paid by a second-tier subsidiary, provided that the Norwegian parent indirectly holds at least 25% of the second-tier subsidiary and that the second-tier subsidiary is a resident of the same country as the first-tier subsidiary. The regime also applies to dividends paid out of profits that have been retained by the first- or second-tier subsidiary for up to four years after the year the profits were earned. The tax credit applies only to tax paid to the country where the first- and second-tier subsidiaries are resi dent.
C. Determination of taxable income
General. In calculating taxable income, book income shown in the annual financial statements (which must be prepared in accor dance with generally accepted accounting principles) is used as a starting point. However, the timing of income taxation is based on the realization principle. Consequently, the basic rules are that an income is taxable in the year in which the recipient obtains an unconditional right to receive the income, and an expense is de ductible in the year in which the payer incurs an unconditional obligation to pay the expense. In general, all expenses, except gifts and entertainment expenses, are deductible.
Inventory. Inventory is valued at cost, which must be determined on a first-in, first-out (FIFO) basis.
Depreciation. Depreciation on fixed assets must be calculated using the declining-balance method at any rate up to a given maximum. Fixed assets (with a cost of more than NOK15,000 and with a useful life of at least 3 years) are allocated to one of the following 10 different groups.
Maximum depreciation
Group rates (%)
A Office equipment and similar items 30
B Acquired goodwill 20
C Specified vehicles
Trailers, trucks and buses 24
Commercial vehicles, taxis and vehicles for the transportation of disabled persons 24 Electric trucks acquired on or after 20 December 2016 30
D Cars, tractors, other movable machines, other machines, equipment, instruments, furniture, fixtures and similar items 20
E Ships, vessels, drilling rigs and similar items 14
F Aircraft and helicopters 12
G Installations for transmission and distribution of electric power, electronic equipment in power stations and such production equipment used in other industries
Maximum depreciation Group rates (%)
H Industrial buildings and industrial installations, hotels, rooming houses, restaurants and certain other structures
Useful life of 20 years or more
Useful life of less than 20 years
Livestock buildings in the agricultural sector
Office buildings
Technical installations in buildings
Assets in groups A, B, C and D are depreciated as whole units, while assets in groups E, F, G, H, I and J are depreciated individually.
If fixed assets in groups A, B, C and D are sold, the proceeds reduce the balance of the group of assets and consequently the basis for depreciation. If a negative balance results within groups A, C or D, part of the negative balance must be included in income. In general, the amount included in income is determined by mul tiplying the negative balance by the depreciation rate for the group. However, if the negative balance is less than NOK15,000, the entire negative balance must be included in taxable income.
A negative balance in one of the other groups (B, E, F, G, H, I and J) must be included in a gains and losses account. Twenty percent of a positive balance in this account must be included annually in taxable income.
Relief for losses. A company holding more than 90% of the shares in a subsidiary may form a group for tax purposes. To consolidate taxable income in a tax group, a company with net profits may transfer those profits to a loss-making company. The profits are required to be actually transferred between the group companies. Companies covered by the financial tax (see Financial tax in Section B) may only deduct 22/25 of intragroup contributions to companies not covered by the financial tax.
Effective from the 2021 income year, Norwegian companies may grant tax-deductible group contributions to subsidiaries that are resident in an EEA country, provided that certain conditions are fulfilled. The group contribution must cover a final loss in the subsidiary, in line with the principles established under EU case law.
Alternatively, losses may be carried forward indefinitely. Losses can only be carried back when a line of business has been termi nated. Losses may be carried back to offset profits of the preced ing two years.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate (%)
Value-added tax, on any supply of goods and services, other than zero-rated (0%) and exempt (without credit) supplies, in Norway
General rate
Nature of tax Rate
Passenger transportation, cultural events and certain other supplies 12 Social security contributions, on all taxable salaries, wages and allowances, and on certain fringe benefits; paid by Employer (general rates; lower in some municipalities and for employees age 62 and over)
Employee (expatriates liable unless exempt under a social security convention)
Professional income
Pensioners and persons under 17 years old
E. Miscellaneous matters
Anti-avoidance legislation. According to a general anti-avoidance provision in Norwegian legislation, tax authorities may disregard a transaction if its main purpose is to obtain a tax benefit and, after an overall assessment, it is determined that the transaction cannot be used as the basis for taxation. The determination of whether the main purpose is to obtain a tax benefit is dependent on an objective assessment (that is, an assessment of what a hypothetical rational taxpayer would have done in a similar situ ation instead of the specific taxpayer).
In addition, Norwegian legislation has a specific anti-avoidance rule. If a company with a general tax position (that is, a tax posi tion not connected to any specific asset or debt, such as a tax loss carryforward) is involved in a transaction in which the use of that tax position is the main objective of the transaction, the tax authorities may disallow such a tax position. This rule has a narrower scope, but a lower threshold for application, than the gen eral anti-avoidance provision described above.
Foreign-exchange controls. Norway does not impose foreignexchange controls. However, foreign-exchange transactions must be carried out by approved foreign-exchange banks.
Debt-to-equity rules. Norway does not have statutory thincapitalization rules. Based on the arm’s-length principle (see Transfer pricing), the tax authorities may deny an interest deduction on a case-by-case basis if they find that the equity of the company is not sufficient (for example, the Norwegian debtor company is not able to meet its debt obligations). An allocation rule regulates the deductibility of interest expenses for income subject to petroleum tax.
Norway has interest limitation rules. Under these rules, interest payments that exceed 25% of “tax earnings before interest, tax, depreciation and amortization (EBITDA),” which is defined as ordinary taxable income with tax depreciation and net interest expenses added back, are nondeductible (fixed ratio rule).
These rules impose a general restriction on interest deductibility, which applies to corporations and transparent partnerships as well as Norwegian permanent establishments of foreign companies. The restriction applies to interest payments made in both domestic and cross-border situations. With respect to companies that are not part of a group, only interest paid to related persons are covered
by the fixed ratio rule. Companies that are part of a consolidated multinational group for financial accounting purposes or companies that can be part of such group (group companies) are subject to the fixed ratio rule on interest paid on both internal and external loans. Companies taxed under the tonnage tax regime and under the hydropower tax regime are also subject to the fixed ratio rule. However, entities subject to the Norwegian Petroleum Tax Act are not yet covered by the rules.
The fixed ratio rule applies only if net interest expenses exceed the threshold established by the law. For group companies, the threshold is NOK25 million, which is computed on a combined basis for all Norwegian entities in the global consolidated group. For companies that are not part of a group, the threshold is NOK5 million. If the applicable threshold is exceeded, all interest expenses must be assessed under the fixed ratio rule, including the first NOK25 million or NOK5 million.
There are two alternative equity escape rules that may apply to group companies if the threshold of NOK25 million is exceeded.
The first equity escape rule allows all interest expenses to be deducted if the Norwegian company can demonstrate that its adjusted equity over total assets ratio (equity ratio) is no more than two percentage units (points) lower than the equivalent eq uity ratio of the global group.
The second equity escape rule allows all interest expenses to be deducted if the combined Norwegian part of the group can dem onstrate that its adjusted equity ratio is no more than two percent age units lower than the equivalent equity ratio of the global group.
Certain exceptions apply to interest expenses incurred by group companies on borrowing arrangements with related parties that are not part of the consolidated group. For such related-party interest, the equity escape rules do not apply and, if net interest expenses in the borrowing entity exceed NOK5 million, the net related-party interest can be deducted only to the extent both internal and external net interest expenses do not exceed 25% of tax EBITDA.
Under the rules, a related party is a person, company or entity if, at any point during the fiscal year, any of the following is true:
• It directly or indirectly controls at least 50% of the debtor.
• It is a company or entity of which the debtor directly or indi rectly controls at least 50%.
• It is a company or entity that is at least 50% owned directly or indirectly by the same company or entity as the debtor.
In general, interest expenses that cannot be deducted during the fiscal year can be carried forward for 10 years. However, the in terest expenses carried forward cannot exceed 25% of the basis of the calculation to be made in any future year. Any carryforward of non-deducted interest expenses must be deducted before the current year’s interest expenses.
Controlled foreign companies. Norwegian shareholders in con trolled foreign companies (CFCs) resident in low-tax jurisdic tions are subject to tax on their allocable shares of the profits of the CFCs, regardless of whether the profits are distributed as
dividends. A CFC is a company of which 50% or more of its shares is directly or indirectly owned or controlled by Norwegian residents. A low-tax jurisdiction is a jurisdiction with an effective corporate tax rate for that kind of company that is less than twothirds of the Norwegian effective tax rate that would have been imposed if the taxpayer had been resident for tax purposes in Norway. The CFC rules do not apply to the following CFCs:
• A CFC resident in a country with which Norway has entered into a tax treaty if the income of the CFC is not of a predominantly passive nature.
• A CFC resident in an EEA member country if such CFC is actually established and carries out genuine economic activities in its home country and if Norway and the home country have entered into a treaty containing exchange-of-information provi sions. As of 2019, Norway has entered into such treaties with all EEA countries.
The losses of a CFC may not offset the non-CFC income of an owner of the CFC, but they may be carried forward to offset future profits of the CFC.
Transfer pricing. The arm’s-length principle is stated in Section 13-1 of the Tax Act, and the transfer-pricing filing and documen tation requirements are stated in Section 8-11 of the Tax Administration Act. Norway has not yet formally implemented the changes for transfer-pricing documentation set out in Chapter V of the 2017 Organisation for Economic Co-operation and Development (OECD) Transfer Pricing Guidelines. However, the Norwegian Ministry of Finance and the tax administration in Norway have communicated that the new rules will be formally implemented. In practice, transfer-pricing documentation in line with Chapter V of the 2017 OECD Transfer Pricing Guidelines is accepted as long as it also fulfills the more specific Norwegian requirements set out in Section 8-11 of the Tax Administration Act. As an attachment to the annual tax return, Norwegian com panies and Norwegian permanent establishments must report summary information about their business and their controlled transactions (Form RF-1123) with affiliated companies.
Norwegian companies and Norwegian permanent establishments must prepare and maintain annual written documentation describing their group, the Norwegian entities and their signifi cant controlled transactions and dealings with related parties. To avoid a deemed tax assessment, such documentation must be presented to the tax authorities no later than 45 days after it has been requested. The statutory limitation for providing such docu mentation is 10 years.
Companies that meet the following criteria for the relevant tax year are exempt from the documentation requirements:
• The real value of the controlled (intercompany) transactions is less than NOK10 million during the fiscal year.
• At the end of the relevant tax year, the intercompany loans, debts, guarantees and receivables amount to less than NOK25 million.
In addition, Norwegian entities belonging to a group of compa nies with less than 250 employees may be exempted from the abovementioned documentation requirements if the group has consolidated sales revenue of less than NOK400 million or a
consolidated total balance of less than NOK350 million. The exemption does not apply if the Norwegian entity has controlled transactions with related parties located in countries from which Norwegian tax authorities cannot request exchange of informa tion under a treaty. The exemption also does not apply to compa nies subject to tax under the Norwegian Petroleum Tax Act.
Country-by-Country Reporting. Norway has introduced Countryby-Country Reporting (CbCR) requirements that mainly follow OECD BEPS Action 13 requirements. The CbCR requirements apply to Norwegian entities that are part of a multinational group of companies with consolidated turnover exceeding NOK6.5 billion. Any Norwegian entity that is part of such group of companies must notify the Norwegian tax authorities about the reporting entity for the group in the annual tax return (Form RF-1028) concerning the reporting year, at the latest. The requirements are stated in Section 8-12 of the Tax Administration Act.
F. Treaty withholding tax rates
On 21 December 2020, the Norwegian parliament adopted rules imposing a 15% withholding tax on interest, royalties and certain lease payments to related parties resident in a low-tax jurisdiction. For the purpose of the rules, a company is considered a “related party” if the payer and the recipient are directly or indi rectly under the same ownership and control by at least 50%. The term “low-tax jurisdiction” is to be interpreted in line with the controlled foreign company rules (see Section E). The rules entered into force on 1 July 2021 for interest and royalties. Consequently, the treaty rates listed below for interest and royal ties may apply from 1 July 2021, subject to the fulfillment of requirements (if any) established in each treaty.
Many treaties provide exemptions for dividend, interest and roy alties paid to certain entities (for example, to the state, local authorities, the central bank, export credit institutions or with respect to sales on credit). Such exemptions are not considered in the table below.
Dividends Interest Royalties % % %
Albania 5/15 (c) 10 10
Argentina 10/15 (c) 12 (u) 3/5/10/15 (dd)
Australia 0/5/15 (n) 0/10 (v) 5
Austria (a)(b) 0/15 (o) 0 0
Azerbaijan 10/15 (k) 10 10 Bangladesh 10/15 (d) 10 10 Barbados 5/15 (d) 5 5 Belgium (a)(b) 0/5/15 (d) 0/10 (uu) 0
Benin 18 25 0
Bosnia and Herzegovina (f) 15 0 10 Brazil (b) 25 15 15
Bulgaria 5/15 (d) 5 5 Canada (b) 5/15 (d) 10 0/10 (ee)
Chile 5/15 (c) 4/5/15 (w) 2/10 (ff)
China Mainland (b)(m) 15 10 10
Côte d’Ivoire 15 16 10 Croatia (f) 15 0 10
Cyprus (a)
Dividends Interest Royalties % % %
0/15 (d) 0 0
Czech Republic (a)(e) 0/15 (d) 0 0/5/10 (gg)
Denmark (a) (Nordic Treaty)
0/15 (d) 0 0
Egypt (b) 15 0 15 (hh)
Estonia (a) 5/15 (c) 10 0 (ii)
Faroe Islands (Nordic Treaty) 0/15 (d) 0 0
Finland (a) (Nordic Treaty)
0/15 (d) 0 0 France (a)(b) 0/5/15 (i) 0 0
Gambia 5/15 (c) 15 12.5
Georgia 5/10 (d) 0 0 Germany (a)(b) 0/15 (c) 0 0
Greece (a) 20 10 10 Greenland 5/15 (d) 0 10 Hungary (a) 10 0 0 Iceland (a) (Nordic Treaty)
0/15 (d) 0 0 India 10 10 10 Indonesia 15 10 10/15 (jj)
Ireland (a) 5/15 (d) 0 0 Israel (b) 5/15 (g) 25 10 Italy (a)(b) 15 15 5 Jamaica 15 12.5 10 Japan 5/15 (c) 10 10 Kazakhstan 5/15 (d) 10 10 (kk) Kenya 15/25 (c) 20 20 Korea (South) (b) 15 15 10/15 (ll) Latvia (a)(b) 5/15 (c) 10 0/5/10 (mm)
Lithuania (a) 5/15 (c) 10 0/5/10 (mm)
Luxembourg (a) 5/15 (c) 0 0
Malawi 5/15 (d) 10 5 Malaysia (b) 0 0 0
Malta (a) 0/15 (r) 0 0
Mexico 0/15 (c) 10/15 (x) 10
Montenegro (f) 15 0 10
Morocco 15 10 10
Nepal 5/10/15 (h) 10/15 (y) 15 (kk)
Netherlands (a) 0/15 (d) 0 0
Netherlands Antilles 5/15 (c) 0 0
New Zealand (b) 15 10 10
North Macedonia 10/15 (c) 5 5
Pakistan 15 10 12 Philippines 15/25 (d) 15 10 Poland (a) 0/15 (d) 5 5 Portugal (a) 5/15 (s) 10 10
Qatar 5/15 (d) 0 5 Romania 5/10 (d) 5 5
Russian Federation 10 10 0
Senegal 16 16 16
Serbia 5/15 (c) 10 (vv) 5/10 (nn)
Sierra Leone 0/5 (g) 0 0
Singapore (b) 5/15 (c) 7 7
Slovak
Republic (b)(e)
Dividends Interest Royalties % % %
5/15 (c) 0 0/5 (oo)
Slovenia 0/15 (q) 5 5
South Africa 5/15 (c) 0 0
Spain (a)(b) 10/15 (c) 0/10 (z) 0/5 (ww)
Sri Lanka 15 10 10
Sweden (a) (Nordic Treaty) 0/15 (d) 0 0
Switzerland (b) 0/15 (d) 0 0
Tanzania 20 15 20
Thailand (b) 10/15 (d) 10/15 (aa) 5/10/15 (pp)
Trinidad and Tobago 10/20 (c) 15 15
Tunisia 20 12 5/15/20 (qq)
Turkey 5/15 (p) 5/10/15 (bb) 10
Uganda 10/15 (c) 10 10
Ukraine 5/15 (c) 10 5/10 (rr)
United Kingdom 0/15 (t) 0 0
United States (b) 15 0/10 (xx) 0 (ss)
Venezuela 5/10 (d) 5/15 (cc) 9/12 (tt)
Vietnam 5/10/15 (j) 10 10
Zambia 5/15 (l) 10 10
Zimbabwe 15/20 (c) 10 10
Non-treaty
jurisdictions 25 0/15 0/15
(a) Dividends paid to corporate residents of EEA member states are exempt from withholding tax if the EEA resident company is really established in its home country.
(b) A revision of this treaty (or a new protocol) is currently being negotiated. Also, see the first paragraph after the footnotes.
(c) The treaty withholding rate is increased if the recipient is not a company owning at least 25% of the distributing company. For Serbia, in order to be entitled to this reduced rate, the recipient must also fulfill a holding period in accordance with the provisions of Article 8 of the Multilateral Instrument to Implement Tax Treaty Measures to Prevent Base Erosion and Profit Shifting (MLI). The holding period applies to dividend payments from 1 January 2020. For Kenya, the withholding rate is increased if the recipient is not a company owning at least 25% of the distributing company during the period of six months immediately preceding the date of payment of the dividends.
(d) The treaty withholding rate is increased if the recipient is not a company owning at least 10% of the distributing company. For Ireland and the Netherlands, in order to be entitled to this reduced rate, the recipient must also fulfill a holding period in accordance with the provisions of Article 8 of the MLI. The holding period applies to dividend payments from 1 January 2020. For Poland, the 0% rate applies if the Polish company owns directly at least 10% of the capital in the Norwegian company for an uninterrupted period of at least 24 months. For Belgium, the 5% rate applies if the benefi cial owner is a pension fund that satisfies additional conditions established in the treaty. The 0% rate applies if the beneficial owner of the dividends owns directly at least 10% of the capital in the Norwegian company for an uninter rupted period of at least 12 months.
(e) Norway honors the Czechoslovakia treaty with respect to the Slovak Republic. Norway has entered into a tax treaty with the Czech Republic. The withhold ing tax rates under the Czech Republic treaty are shown in the above table.
(f) Norway honors the suspended Yugoslavia treaty with respect to Bosnia and Herzegovina, Croatia and Montenegro.
(g) The treaty withholding rate is increased if the recipient is not a company holding at least 50% of the voting power of the distributing corporation.
(h) The 5% rate applies if the recipient is a company owning at least 25% of the distributing company. The rate is increased to 10% if the recipient is a company owning at least 10%, but less than 25%, of the distributing com pany. For other dividends, the rate is 15%.
(i) The 0% rate applies if the recipient company owns at least 25% of the capital in the Norwegian company. The 5% rate applies if it owns at least 10% of the capital in the Norwegian company but less than 25%. The 15% rate applies if the beneficial owner owns less than 10% of the capital in the Norwegian company.
(j) The 5% rate applies if the recipient of the dividends owns at least 70% of the capital of the Norwegian payer. The rate is increased to 10% if the recipient owns at least 25%, but less than 70%, of the Norwegian payer. For other dividends, the rate is 15%.
(k) The treaty withholding rate is increased to 15% if the recipient is not a com pany that satisfies both of the following conditions:
• It owns at least 30% of the capital of the distributing company.
• It has invested more than USD100,000 in the payer.
(l) The 5% rate applies if the beneficial owner is a company (other than a part nership) that holds directly at least 25% of the capital of the distributing company.
(m) The Hong Kong and Macau Special Administrative Regions (SARs) are not covered by the China Mainland treaty.
(n) The 5% rate applies if the Australian company holds at least 10% of the vot ing power in the Norwegian company and fulfills the required holding period in accordance with the provisions of Article 8 of the MLI. The holding period applies to dividend payments from 1 January 2020. The 0% rate applies if more than 80% of the voting power is held, subject to several conditions.
(o) The 0% rate applies if the recipient is a company.
(p) The 5% rate applies if the dividends are exempt in Norway and if they are derived by either of the following:
• A beneficial owner (other than a partnership) who holds directly at least 20% of the capital in the Norwegian company
• The Government Social Security Fund (Sosyal Güvenlik Fonu)
(q) The treaty withholding rate is increased if the recipient is not a company owning at least 15% of the distributing company and/or does not fulfill the required holding period in accordance with the provisions of Article 8 of the MLI. The holding period applies to dividend payments from 1 January 2020. The 0% rate applies if more than 80% of the voting power is held, subject to several conditions.
(r) The 0% rate applies if the beneficial owner is one of the following:
• A company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividends on the date on which the divi dends are paid if it has maintained that holding for an uninterrupted 24-month period or if it will maintain that holding for an uninterrupted 24-month period in which that date falls
• A statutory body or an institution wholly or mainly owned by the govern ment of Malta or the Central Bank of Malta
(s) The treaty withholding tax rate is increased if the recipient is not a company directly owning at least 10% of the distributing company for the last 12 months. If the distributing company has existed for less than 12 months, the recipient must satisfy the 10% condition since the date on which the distribut ing company was established.
(t) The treaty withholding tax rate is increased if the recipient is not a company owning, directly or indirectly, at least 10% of the distributing company or is a pension scheme.
(u) The rate under the treaty is 12.5%. However, as a result of a most-favorednation clause, the rate is reduced to 12%.
(v) The 0% rate applies to interest is derived from the investment of official reserve assets by the government of a contracting state, its monetary institu tions or a bank performing central banking functions in that state or interest derived by a financial institution that is unrelated to and dealing wholly independently with the payer. However, a 10% rate applies if the interest is paid as part of an arrangement involving back-to-back loans, or other arrangements that are economically equivalent and intended to have a similar effect. The 10% rate applies in all other cases.
(w) The 5% rate applies to interest derived from bonds or securities that are regu larly and substantially traded on a recognized securities market. The 4% rate applies if the beneficial owner is one of the following:
• A bank
• An insurance company
• An enterprise substantially deriving its gross income from the active and regular conduct of a lending or finance business involving transactions with unrelated persons if the enterprise is unrelated to the payer of the interest
• An enterprise that sold machinery or equipment if interest is paid with respect to indebtedness that arises as part of the sale on credit of such machinery or equipment
• Any other enterprise, provided that in the three tax years preceding the tax year in which the interest is paid, the enterprise derives more than 50% of its liabilities from the issuance of bonds in the financial markets or from the taking of deposits at interest, and more than 50% of the assets of the enterprise consist of debt-claims against unrelated persons
The 15% rate applies in all other cases.
(x) The 10% rate applies to interest paid to banks.
(y) The 10% rate applies to interest paid to banks carrying on bona fide banking business.
(z) The 0% rate applies to interest on certain qualifying loans.
(aa) The 10% rate applies to interest paid to financial institutions (including insur ance companies). A most-favored-nation clause may apply with respect to interest payments.
(bb) The 5% rate applies to certain credit institutions providing export credits or a government pension or social security fund. The 10% rate applies to interest paid to banks. The 15% rate applies in all other cases.
(cc) The 5% rate applies to interest paid to banks.
(dd) The 3% rate applies to news-related royalties. The 5% rate applies to copy right royalties other than royalties related to films or tapes. The 10% rate applies to patents, trademarks, know-how, certain lease-related royalties and technical assistance. The 15% rate applies in all other cases. A most-favorednation clause may apply with respect to royalty payments.
(ee) The 0% rate applies to copyright royalties (excluding films), computer soft ware, patents and know-how.
(ff) The royalties’ rates under the treaty are 5% for equipment leasing and 15% in all other cases. However, as a result of a most-favored-nation clause, the rates are reduced to 2% for equipment leasing and 10% in all other cases.
(gg) The 0% rate applies to copyrights of literary, artistic or scientific works except for computer software and including cinematographic films, and films or tapes for television or radio broadcasting. The 5% rate applies to indus trial, commercial or scientific equipment. The 10% rate applies to patents, trademarks, designs or models, plans, secret formulas or processes and com puter software, or for information concerning industrial, commercial or sci entific experience.
(hh) The reduced rate does not apply to royalties with respect to cinematographic films.
(ii) The rates for royalties under the treaty are 5% for equipment rentals and 10% in all other cases. However, as a result of a most-favored-nation clause, royal ties are exempt from withholding tax.
(jj) The 10% rate applies for the use of any patents, trademarks, designs or mod els, plans, secret formulas or processes, and for the supply of commercial, industrial or scientific equipment or information. The 15% rate applies for the use of, or the right to use, copyrights of literary, artistic or scientific works, including cinematographic films or films or tapes for radio or televi sion broadcasting.
(kk) A most-favored-nation clause may apply with respect to royalties.
(ll) The 10% rate applies for the use of any patents, trademarks, designs or mod els, plans, secret formulas or processes, and for the supply of commercial, industrial or scientific equipment or information. The 15% rate applies for the use of, or the right to use copyrights of literary, artistic or scientific works, including cinematographic films.
(mm) The 5% rate applies to royalties paid for the use of industrial, commercial or scientific equipment. The 10% rate applies to all other cases. A most-favorednation clause may apply with respect to royalties, reducing the rate to 0%.
(nn) The 5% rate applies to royalties paid for the use of, or the right to use copy rights of literary, artistic or scientific works, including cinematographic films or films or tapes used for radio or television broadcasting. The 10% rate applies to royalties paid for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for infor mation concerning industrial, commercial or scientific experience. A mostfavored-nation clause may apply with respect to interest payments.
(oo) The 5% rate applies for the use of or the right to use patents, trademarks, designs or models, plans, secret formulas or processes, or industrial, com mercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience. The 0% rate applies to royalties paid for the use of or the right to use copyrights of literary, artistic or scientific works, including cinematographic films, and films or tapes for television or radio broadcasting.
(pp)
The 5% rate applies for the use of, or the right to use, copyrights of literary, artistic or scientific works. The 10% rate applies to royalties for the use of or the right to use industrial, commercial or scientific equipment. The 15% rate applies in all other cases.
(qq) The 5% rate applies for the use of, or the right to use, copyrights of literary, artistic or scientific works, excluding cinematographic films or films for television broadcasting. The 15% rate applies for the use of patents, models, secret formulas or processes, or for information concerning industrial, com mercial or scientific experience. The 20% rate applies for the use of, or the right to use, licensing rights, manufacturing rights or trademarks, cinemato graphic films or films for television broadcasting and equipment used in agricultural, industrial or scientific research.
(rr) The 5% rate applies for the use of patents, plans, secret formulas or pro cesses, or for information (know-how) concerning industrial, commercial or scientific experience. The 10% rate applies in all other cases.
(ss) The reduced rate does not apply to royalties for copyrights of motion picture films or films or tapes used for radio or television broadcasting.
(tt) The 9% rate applies to payments for technical assistance. The 12% rate applies in all other cases.
(uu) The 0% rate applies if one of the following conditions are met:
• The interest is paid by a purchaser to a seller in connection with a com mercial credit resulting from deferred payments for goods, merchandise, equipment or services.
• The interest is paid with respect to loans of any nature granted by a bank ing enterprise, except when such loans are represented by bearer instru ments.
• The interest is paid with respect to a credit or loan of any nature granted or extended by an enterprise to another enterprise.
• The interest is paid to a pension fund, provided that the debt-claim with respect to which such interest is paid is held for the purpose of certain activities.
(vv) A most-favored-nation clause may apply with respect to interest payments.
(ww) The 0% rate applies to royalties received in consideration for the use of, or the right to use, ships or aircraft on a bareboat basis, or containers, in inter national traffic. The 5% rate applies in all other cases.
(xx) The 0% rate applies to interest paid by a purchaser to a seller in connection with commercial credit resulting from deferred payments for goods, mer chandise or services and interest paid with respect to a loan of any nature made by a bank.
Norway signed a tax treaty with Ghana on 20 November 2020, but the treaty is not yet in force. Norway is negotiating tax trea ties with the Hong Kong SAR, Iran, Kuwait and Liechtenstein.
Norway has entered into exchange-of-information tax treaties with Andorra, Anguilla, Antigua and Barbuda, Aruba, Bahamas, Bahrain, Belize, Bermuda, Botswana, British Virgin Islands, Brunei Darussalam, Cayman Islands, Cook Islands, Costa Rica, Denmark (Nordic Treaty), Dominica, Faroe Islands (Nordic Treaty), Finland (Nordic Treaty), Gibraltar, Grenada, Guernsey, the Hong Kong SAR, Iceland (Nordic Treaty), Isle of Man, Jersey, Liberia, Lichtenstein, the Macau SAR, Marshall Islands, Mauritius, Monaco, Montserrat, Niue, Panama, Samoa, San Marino, Seychelles, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, the Turks and Caicos Islands, the United Arab Emirates, the United States, Uruguay and Vanuatu.
In addition, Norway signed an exchange-of-information tax treaty with Guatemala on 15 May 2012, but the agreement is not yet in force.