Details of the amending protocol to the Germany - Norway Income and Capital Tax Agreement (1991), signed on 24 June 2013, have become available. The protocol was concluded in the German and Norwegian languages, each text having equal authenticity. The most important amendments contained in the protocol are:
|-||introduction of a new article 7 on business profits in line with article 7 of the OECD Model (2010);|
|-||a withholding tax rate of 0% on dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of the company paying the dividends (15% in other cases);|
|-||a new article 18(1) according to which pensions and other similar remuneration, as well as payments under a social security system, paid to a resident of a contracting state, may also be taxed in the source state, but the tax so charged must not exceed 15% of the gross amount of the payments;|
|-||introduction of a subject-to-tax clause in order to avoid double non-taxation (article 23(2)(a)); and|
|-||an exchange of information provision in line with article 26 of the OECD Model (2010).|
The protocol will enter into force on the day of the exchange of the instruments of ratification and will be applicable as from 1 January of the year of its entry into force.
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