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The government of Norway has submitted a new protocol to the Norway-Switzerland tax treaty to the parliament for ratification. Under the protocol, the rate of withholding tax for dividends will be reduced to nil for corporate shareholders holding 20% or more of the share capital of the distributing company. For other shareholders, the withholding tax rate will remain at 15%. A deadline of 3 years for reclaiming excessive withholding tax will be introduced by a new provision to the treaty.

09 June 2005|Treaty Development|Norway-Switzerland

Under the terms of the protocol, the method for the avoidance of double taxation in Norway is changed from the exemption method to the credit method. Exemption with progression may still be applied for pension income and for income from government service.

If the protocol enters into force in 2005, it will apply for all dividend payments in 2005 and for other purposes from 1 January 2006.

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