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Protocol to the Tax Treaty between Germany and Norway has Entered into Force

|Treaty Development|Germany-Norway
Germany-Norway

On 3 February 2015, the protocol to the 1991income and capital tax treaty between Germany and Norway entered into force. The protocol, signed 24 June 2013, is the first to amend the treaty. The main amendments include:

  • Article 7 Business Profits is replaced in line with OECD Model (2010)
  • Article 10 Dividends is replaced, with the new article including that the withholding tax rates on dividends is 0% if the beneficial owner is a company directly holding at least 25% of the paying company's c…

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