Norway: New reclaim form published by the Norwegian Tax Authorities
Clearstream Banking1 would like to inform customers that the Norwegian Tax Authorities have released a new reclaim form to be used, when reclaiming withholding tax on Norwegian dividends on behalf of beneficial owners that are either:
- A resident of a Double Taxation Treaty country; or
- A foreign entity resident in a European Economic Area (EEA) qualifying for the tax-exemption model
The new reclaim form Application for Refund of Norwegian Withholding Tax, available below and from our Tax forms to use - Norway page, includes the following requirements:
Section 1 - Claimant
This section should be completed with the beneficial owner’s and representative’s details, as applicable.
Section 2 - Dividends
This section should be completed with the relevant details of the dividends for which the beneficial owner is reclaiming the withholding tax.
The part “Norwegian Central Securities Depository account number” should be left blank as Clearstream will provide this information to the Norwegian Tax Authorities.
Section 3 - Information regarding organisational structure
This section should be completed by beneficial owners that are foreign entities resident in a European Economic Area (EEA) and applying for the tax-exemption model.
Section 4 - Payment details
This section should be completed with the payment details of Clearstream. Clearstream have therefore for the convenience of our customers prepared a prefilled sample of the reclaim form Application for Refund of Norwegian Withholding Tax, available below and from our Tax forms to use - Norway page, which includes the payment details of Clearstream.
Note: If the form is downloaded directly from the Norwegian Tax Authorities website, then it will be mandatory to leave this section blank, as the reclaim form will otherwise be rejected by Clearstream.
Section 5 - Certificate of Residence (COR) issued by the Competent Authority in the country of permanent residence
This section is to be completed by the beneficial owner’s local tax authority.
Alternatively, a separate COR is also acceptable, if the COR includes the following information:
- The beneficial owner’s full name and address;
- Tax identification number;
- State that the beneficial owner was resident according to the tax treaty with Norway (for standard refund applications under the tax exemption method Norwegian Tax Act Section 2-38, fifth paragraph, the COR does not have to refer to the tax treaty with Norway); and
- Is valid for the year when the dividend was distributed, meaning, the tax authorities must certify on the COR that the beneficial owner was resident for the period, when the dividend distribution was made.
Furthermore, if the beneficial owner is reclaiming for more than one dividend payment of the same payment year, then one original COR is sufficient to be provided for the first reclaim application for that specific year and copies may hereafter be provided by the beneficial owner for the other reclaims sent later on, if related to the same payment year.
Impact on customers
The current Clearstream reclaim template Request to the Norwegian Tax Authorities for Tax refund, available from our Tax forms to use - Norway page, remains valid. However, customers are recommended to start using the new official form, when applying for standard refund on behalf of beneficial owners that are resident of a Double Taxation Treaty country or foreign EEA entities qualifying for the tax-exemption model.
All other documentation requirements remain as per current process, when submitting standard reclaim applications via Clearstream,
Customers are furthermore reminded that the Norwegian Tax Authorities will assess each tax reclaim request received individually and may at any time request such additional supporting documentation, which they deem necessary to determine the beneficial owner’s eligibility for a reclaim of the requested amount.
For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for CBF customers using CreationOnline), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.