Executive summary
In the Norwegian Ministry of Finance’s (the Ministry) proposal for the 2021 State Budget published on 7 October 2020, the Ministry introduced a 15% withholding tax (WHT) on interest, royalties and certain lease payments to related entities resident in a low-tax jurisdiction. If passed, the effective date would be 1 July 2021.
This WHT may be reduced or exempt under the provisions of a tax treaty entered into by Norway or when the recipient is a company that is actually …