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HMRC internal manual

Double Taxation Relief Manual

Norway: dividends

Dividends paid by companies resident in Norway and beneficially owned by a resident of the UK are exempt from tax in Norway where the beneficial owner is:

  • A company which owns, directly or indirectly, 10% or more of the capital in the paying company;
  • A pension scheme; or
  • The United Kingdom Government (including the Bank of England and institutions wholly or partly owned by the United Kingdom Government)

Dividends beneficially owned by persons other than those listed above are taxable in Norway at a rate not exceeding 15%.

The reduction in domestic rates is not given where the dividends are effectively connected with (see INTM153110 eighth sub-paragraph) a business carried on by the United Kingdom resident recipient through a permanent establishment in Norway.