Relief at source – Norwegian equities
Reference
Dividend payments distributed from Norwegian equities are subject to 25% withholding tax by default in Clearstream.
Eligible beneficial owners
The following beneficial owners are eligible to obtain relief at source from withholding tax on dividend payments on Norwegian equities:
Equities | |
Beneficial owner | Tax rate |
Non-resident of a DTT country | DTT |
Non-resident EEA entities qualifying for the tax-exemption method – Note a | 0% |
0% |
Documentation requirements
For the purpose of obtaining relief or exemption at source on behalf of eligible beneficial owners, clients must submit to Clearstream, before the relevant deadlines, the following documentation:
Documents | Individuals resident in a DTT country | Legal entities resident in a DTT country – claiming reduced tax rate under the DTT | Legal entities resident in a DTT country – claiming full tax exemption under the DTT | Foreign EEA entities qualifying for the Tax Exemption Model | Luxembourg SICAVs organised as UCITS qualifying for the Tax Exemption Model | International organisations and foreign governments qualifying for tax exemption |
One-Time Certificate for Norwegian Equities | X | X | X | X | X | X |
Per-payment instruction | X | X | X | X | X | X |
Certificate of Residence (COR)d | X | X | X | X | X | |
Beneficial owner certificate | X | X | X | X | X | X |
Approval letter from the Norwegian Tax Authorities (NTA) | X | X | X | a | X | |
Declaration of unchanged tax status from entities claiming tax exemption | Xb | X | X | |||
Declaration of unchanged tax status from Luxembourgish SICAV organised as UCITS claiming tax exemption | X | |||||
Attestation | X | |||||
Power of Attorneyc | X | X | X | X | X | X |
a. Luxembourgish SICAVs organised as UCITS funds are already pre-approved as tax exempt by the NTA and are therefore not required to provide Clearstream Banking with an approval letter issued by the NTA when claiming tax exemption under the Norwegian Tax Exemption Model. All other documentation is however still required. This exception does however not apply to Luxembourgish SICAVs that are not organised as UCITS funds. These SICAVs are still required to provide the NTA approval letter to Clearstream Banking.
b. Required for legal entities claiming full tax exemption under a DTT, for example eligible Dutch pension funds and UK pension schemes.
c. Only required if the client or a third party is completing a form on behalf of the beneficial owner.
d. a copy of a UCITS attestation issued by an EEA country - for example an attestation, issued by the French "Asset Management Directorate" (AMF) is sufficient documentation of residence and can be used instead of a certificate of residence.
Deadline
The deadlines for the submission of the documentation to obtain relief at source of withholding tax on dividends on Norwegian equities are as follows:
Document | Deadline for receipt by Clearstream |
Approval letter from the Norwegian Tax Authorities | Four business days prior to the record date of the first dividend payment by 10:00 CET |
Attestation | Four business days prior to the record date of the first dividend payment by 10:00 CET |
Beneficial owner certificate | Four business days prior to the record date of the first dividend payment by 10:00 CET |
Four business days prior to the record date of the first dividend payment by 10:00 CET. | |
Declaration of unchanged tax status for entities claiming tax exemption | Four business days prior to the record date of the first dividend payment by 10:00 CET. |
Declaration of unchanged tax status for Luxembourg SICAV organised as UCITs claiming tax exemption | Four business days prior to the record date of the first dividend payment by 10:00 CET. |
Per-payment instruction | One business day after the record date of each dividend payment by 10:00 CET |
One-Time Certificate for Norwegian Equities | Four business days prior to the record date of the first dividend payment by 10:00 CET. |
Power of Attorney | Four business days prior to the record date of the first dividend payment by 10:00 CET. |