
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.