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HMRC internal manual

International Manual

DT Agreements: Norway - Income from a UK source paid to a resident of Norway

UK dividends paid to a resident of Norway - direct investor (Article 10)

See INTM343540 for an explanation of ‘directinvestor’.

Before 6 April 2001 - 1985 Convention: a direct investor company that is thebeneficial owner of the dividends can claim part-payment of tax credit ondividends paid by UK companies on or before 5 April 2001.

The convention (see Article 10) provides that a direct investor company is entitled to atax credit equal to half the tax credit to which a UK individual would be entitled. Andfor the payment of the excess of that tax credit after retention of 10% of the aggregateof the UK dividend plus the half tax credit. Examples of the way in which relief iscalculated can be found at INTM343540.

The anti-dividend stripping provisions of Article 10(6) apply where a direct investorcompany resident in Norway beneficially owns 10% or more of the class of shares from whichthe dividend is paid. The replies to the relevant question on form NOR3/Company/Creditwill enable you to decide whether you need to make dividend stripping enquiries.

See INTM343550 for an explanation of dividend stripping.

After 6 April 2001 - 2000 Convention: There is no provision for paymentof tax credit attached to UK dividends paid on or after the 6 April 2001 to a directinvestor resident in Norway.