On 14 November 2005, Austria-Norway signed a protocol amending their income and capital tax treaty of 28 November 1995. The changes to the 1995 treaty are summarized below.
Dividends
Under the 1995 treaty, intra-group cross-border (minimum shareholding of 25%) dividends are subjected to a withholding tax of 5% which is in line with the OECDE Model Convention. According to the protocol, dividends are exempt from withholding tax if the benefici…