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HMRC internal manual

Double Taxation Relief Manual

Norway: relief from Norwegian tax

Claims to relief from Norwegian tax should be made to the Central Office - Foreign Tax Affairs, Postboks 8031, 4068 Stavanger, Norway.

No special forms are available for this purpose. However, United Kingdom residents who are required by the Norwegian authorities to provide evidence of residence in the United Kingdom should, request a certificate that, for the purposes of United Kingdom tax, they are resident in the United Kingdom for the tax year in question (for example, when the dividend arose) and that they are subject to tax in respect of the income or gain.

The Norwegian authorities may also ask an individual to produce a certificate from the United Kingdom authorities to say that we consider them to be treaty resident here, as well as domestically resident. However, in many cases the United Kingdom will not have considered the claimant’s treaty residence status if it makes no difference to United Kingdom tax. An individual may not have completed the dual resident pages of the SA Return since they are not claiming relief from UK tax.

In such a case the tax office may provide a statement:

  • Confirming that the individual is resident here under our domestic rules and has not made any claim to be treaty resident in Norway;
  • Undertaking that, in the event of such a claim being made, the United Kingdom would consult Norway before accepting the claim.

Relief from Norwegian tax on dividends paid by a company resident in Norway to a resident of the United Kingdom is normally given at source. If relief at source has not been given a United Kingdom resident shareholder may seek repayment from the Central Office - Foreign Tax Affairs. In addition to the certificate referred to above, the claimant should:

  • specify the name of the Norwegian company, the number of shares owned, the date dividend payments were made and the amount of the dividends and Norwegian withholding tax deducted (in Norwegian currency) and
  • confirm that he is the beneficial owner of the dividends.

Where shares in Norwegian companies are registered in the Norwegian Registry of Securities (VPS) in the name of a foreign custodian, trustee, holding agent, or clearing system 25 per cent tax is generally deducted at source. However, on satisfying certain conditions a foreign custodian etc. may obtain permission from the Central Office - Foreign Tax Affairs to register accounts in the VPS at a reduced rate.