Norway: U.S. Regulated Investment Companies (RICs) not eligible for treaty benefits


Further to our tax announcement A17065 dated 11 April 2017 with regard to the Norwegian Tax Authorities (NTA) extending the benefit of the Double Taxation Treaty (DTT) between Norway and the U.S.A. to U.S. RICs, Clearstream Banking1 would like to inform customers that the NTA has now amended its view on the treaty eligibility of U.S. RICs.

The NTA has reached the conclusion that U.S. RICs do not qualify for the reduced treaty benefit of Article 8 of the DTT between Norway and the U.S.A.

Impact on customers

Entities being U.S. RICs and subject to Norwegian dividend withholding tax are no longer entitled to file a refund claim.

Further information

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 Clearstream Banking Frankfurt (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.