Norway: U.S. Regulated Investment Companies may qualify for lower tax on dividends

Clearstream¹ informs clients that in late 2024, Norway and the U.S. signed an agreement under their double taxation treaty (DTT). As a result, U.S. Regulated Investment Companies (RICs) may now qualify for a reduced 15% tax rate on dividends from Norwegian equities.

To benefit from this lower rate, RICs must meet certain conditions that show they are the true owners of the income. These conditions are based on international tax guidelines and include:

• Having many investors (widely held);
• Holding a mix of investments (diversified portfolio);
• Being regulated to protect investors;
• Managing assets independently.

If a U.S. RIC meets these criteria, it may be treated as the beneficial owner and qualify for the reduced tax rate. However, each case is reviewed individually.

Impact on clients

If a client represents U.S. RICs investing in Norway and they meet the above conditions, they can apply to the Norwegian Tax Administration for approval. Clients need to provide documents proving beneficial ownership to get the 15% tax rate.

A qualifying beneficial owner, may consequently apply for a relief at source or standard refund provided the requested documentation has been provided as documented in our Market Taxation Guide – Norway.

Further information

For further information, please contact the Clearstream Tax Help Desk or Clearstream Client Services or your Relationship Officer.

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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 clients using 6-series 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. 
Clearstream Banking S.A. is registered as an Australian CS (Overseas) Facility, under subsection 824B(2) of the Corporations Act 2001, with registration number ARBN 675 244 783.