Norwegian dividend taxation

Norwegian dividend taxation as of 01.01.2019.

As of 1 January 2019, new rules concerning the application of a lower withholding tax rate than 25 per cent will apply on dividend distributions from Norwegian companies to foreign shareholders.

  • Statutory tax rate: 25%
  • Treaty rate for Estonian residents: 15%

Treaty tax rate may be applied if client’s tax residency is Estonia and the client provides valid documents to the bank according to requirements mentioned below.

For application of reduced withholding tax rate, the client has to provide the bank with necessary documents at the latest three business days before dividend ex-date.

The client shall be liable for submission of required documents, also for the accuracy of the documents and payment of all taxes associated with the securities. The bank shall not be liable for damages caused to the client due to applied tax rate or due to failure to submit required documents or to submit these on time. The bank shall not be obliged to remind the client about the need to provide or update documents needed for application of lower tax rate.

Necessary documentation

A certificate of residency (CoR)

Issued by local Tax Authority

Certificate has to refer to Double Taxation Treaty between Estonia and Norway.

As the certificate of residency is valid only for present calendar year, the certificate of residency has to be provided for each year the treaty rate is applied for.

Confirmation from the dividend recipient that they are the beneficial owner of the dividend

Document sample is added. Current document is valid after first submission until underlying circumstances will change and client presents new confirmation.

necessaryDocumentation

A legal person will need to submit the following documents to Swedbank for income tax under the double taxation agreement:

Approval from the Norwegian Tax Administration,

confirming the dividend recipient is entitled to a reduced withholding tax rate.

To obtain this approval, the customer must apply to the Norwegian tax authorities for a more favorable income tax rate or tax exemption to the following address:

Central Tax Office - Foreign Tax Affairs (SFU)
Skatteetaten
Postboks 9200 Grųnland
0134 Oslo
NORWAY

Please note that the above form must contain a residency confirmation from the tax office and the consent obtained will remain in effect until the conditions on which it is based have changed. In this case, the customer must submit a new confirmation.

A certificate of residency (CoR)

Issued by local Tax Authority

Certificate has to refer to Double Taxation Treaty between Estonia and Norway.

As the certificate of residency is valid only for present calendar year, the certificate of residency has to be provided for each year the treaty rate is applied for.

Confirmation from the dividend recipient that they are the beneficial owner of the dividend

Document sample is added. Current document is valid after first submission until underlying circumstances will change and client presents new confirmation.

Confirmation from beneficial owner that their tax status has not changed since the Norwegian Tax Administration gave their approval

If based on the Approval a tax exemption is applied (0%), then the Approval is valid for three years after first submission or until underlying circumstances will change. Client has to provide following confirmation after every three years from initial acceptance.

The confirmation has to be presented before three years have passed from initial Approval date.

  • Required documentation can be presented to the bank starting from 01.01.2019.
  • Documents can be provided to the bank over the year, before dividend ex-date.
  • If required documentation is not provided to the bank before dividend ex-date, then dividend will be paid out with statutory rate (25%).
  • A certificate of residency (issued by local Tax Authority) should be applied starting from year 2019 and should be renewed every year, since it is given only for present calendar year. If dividend ex-date is on Q3, then certificate of residency can be obtained e.g. during summer.
  • General information about the documentation requirements for reduced withholding tax rate.

Process for presenting needed documentation to the bank:

To present documents, choose from menu: My bank → Document management → Document upload

Legal person will upload documents to business client i-bank.

Press the button "Upload new document".

Choose Type → Investment Agreements

Subtype has to be chosen accordingly to uploaded document. Each document is uploaded under separaate, specific subtype. Only relevant subtypes are available for private and corporate customer.

Please revise if you have presented all the necessary documents.

All documents presented to bank have to be manually signed (preferably with blue ink pen)! Manually signed document has to be scanned and uploaded.

Documents are valid until underlying circumstances will change, in which case client has to present new documents and notify bank.