Norway Tax Agency Posts Board Ruling Clarifying Withholding Tax Rules on Dividends for Nonresident Company

The Norwegian Tax Administration March 18 posted online Tax Appeals Board Decision No. SKNS1-2024-136, clarifying the withholding tax rules on dividends for a nonresident company. The taxpayer, a Cyprus-based holding company, had a Swiss owner. The taxpayer sought a refund of withholding tax on dividends under Norway’s exemption method. The Tax Office denied the refund, arguing that the holding company wasn’t genuinely established within the European Economic Area (EEA) and wasn’t the beneficial owner of the dividends. The taxpayer appealed, asserting that it met the criteria for the exemption and the reduced rates under the tax treaty between Norway and ...