Fiscal terms overview and tax balances
Information regarding Norwegian dividend withholding tax
OKEA ASA has paid its first dividends during 2022, and would like to share some general information regarding Norwegian Dividend Withholding Tax (DWT) with respect to dividends paid to non-Norwegian shareholders.
OKEA ASA’s dividend payments, including DWT administration, are handled by DNB on behalf of OKEA ASA.
Norway has a statutory DWT of 25% of dividends distributed to non-Norwegian shareholders. However, this rate may be reduced based on the following:
- General exemption (0%) for dividends paid out of income subject to special petroleum tax if there is an ownership of at least 25%. If such a company also has other ordinary income, there may be an allocation where parts of the dividend are subject to DWT.
- General exemption (0%) for dividends paid to corporate shareholders within EU/EEA, subject to certain requirements (based on the exemption method under the General Tax Act section 2-38)
- Reduction based on the respective tax treaties between Norway and each shareholder’s home country
DWT is a tax at the hands of each recipient of dividends, and thus the sole responsibility of each respective shareholder. However, the distributing company has an obligation to withhold applicable DWT from the respective shareholder’s dividend and make a corresponding payment to the Norwegian tax authorities. The distributing company may be held responsible for too low DWT payment. Thus, unless the shareholder can confirm and document that it is entitled to a lower DWT rate, OKEA ASA will withhold a 25% DWT from the gross dividend. The amount withheld will be paid and reported to the Norwegian Tax Authorities on behalf of the respective shareholders.
For corporate shareholders, it is possible to apply for a pre-approval for reduced or exempted DWT, where the shareholder needs to provide certain documentation to the tax authorities.
For shareholders that are entitled to a lower DWT than actually withheld, it is possible to file for a refund. This needs to be done within 5 years.
Applications for pre-approvals and refund are the responsibility of each shareholder.
Please find two relevant links with information from the Norwegian Tax Authorities:
Dividends from Norwegian companies to foreign shareholders – The Norwegian Tax Administration (skatteetaten.no)
Reduced withholding tax on share dividends for foreign shareholders – The Norwegian Tax Administration (skatteetaten.no)
Finally, paid DWT on dividends from a Norwegian company can give certain possibilities for tax reliefs in the recipient’s home country, depending on tax rules in the home country.
Note: This above is for information only and shall not be considered as legal advice. Securing a correct DWT is the full responsibility of each shareholder.