New rules on the taxation of dividends paid to foreign shareholders

In connection with the implementation of a new tax reform in Norway, important amendments were made in December 2004 and April 2005 to the rules governing the taxation of dividends paid out by Norwegian limited companies, etc. to shareholders who are resident for tax purposes in an EEA state.

These changes entail full exemption from withholding tax subject to specific conditions, on dividends paid out by Norwegian companies to shareholders in Austria, Belgium, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, the Netherlands, Poland, Portugal, Slovakia, Slovenia, Spain, Sweden, and the UK.
 
The Norwegian tax authorities have now laid down guidelines indicating how the tax exemption is to be applied to dividends paid out by Norwegian companies to foreign shareholders. An explanation will be provided below.