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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Norway: interest and royalties

Interest and royalties arising in Norway and beneficially owned by a resident of the United Kingdom are not taxable in Norway.

The reduced rate provided by the treaty is not given if the interest or royalty is effectively connected (see INTM153110 eighth sub-paragraph) with a permanent establishment which the United Kingdom resident recipient has in Norway.