The Norwegian tax administration has published an interpretation statement regarding new documentation rules in order to benefit from a reduced withholding tax rate on dividends paid by companies whose share are not registered with the VPS central securities depository in Norway. The interpretation statement clarifies that in such case, shareholders may benefit from a reduced withholding tax rate if they supply statutory documentation verifying their tax status directly to the company paying the dividends. Further, a reduced withholding tax rate may be applied without the submission of documentation, provided that the company already has the required information to determine the shareholder's tax status. Where the tax status is not known or verified through documentation, the standard 25% withholding tax should be applied. If a dividend-paying company applies a lower rate and is found to be negligent in determining status, the company will be held liable for non-withholding.
The documentation requirements are part of stricter policies regarding dividend withholding tax that will apply from 1 January 2018. With respect to VPS-registered shares, tax status documentation must be submitted to the VPS account operator or custodian in order for a reduced withholding rate to apply. The type of documentation includes a certificate of residence, as well as a prior approval for a withholding tax refund or pre-approval for a lower rate from the tax administration, etc.
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