Norway: UK entities holding pre-approval letters for the Norwegian tax exemption method – Brexit impact
Clearstream Banking1 would like to remind customers that effective
1 January 2021
UK entities currently holding a pre-approval letter, issued by the Norwegian Tax Administration (NTA), which grants tax exemption in accordance with the Norwegian tax exemption method, will no longer be valid post Brexit. This is because one of the prerequisites to qualify for such a rate, is that the beneficial owner must be resident in a country of the European Economic Area (EEA).
Impact on customers
Customers wishing to continue to request relief at source on Norwegian dividends via Clearstream Banking, for the impacted beneficial owner types, must, as of 1 January 2021 and prior to the relevant Clearstream Banking deadline, provide a new valid approval letter should the beneficial owner qualify for a reduced tax rate under the provisions of the Double Taxation Treaty (DTT).
Existing pre-approval forms provided by customers for UK entities claiming exemption under the Norwegian tax exemption model will no longer be valid as of this date.
Customers are further reminded that Clearstream Banking does not assist with obtaining the pre-approval letter. All applications should therefore be submitted directly by the beneficial owner or its representative under power of attorney to the NTA.
The Application – reduced withholding tax rate (double taxation treaty) may be viewed by customers directly on the NTA website.
For further information, customers may contact Clearstream Banking Client Services, their Relationship Officer or Tax Help Desk.
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 AG customers using Creation Accounts), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.