Norway Tax News
Revised Commentary on Article 7 of OECD Model released
28 May 2007
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
28 April 2007
Final Report on Improving the Resolution of Tax Treaty Disputes
24 March 2007
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
24 March 2007
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
24 March 2007
Treaty between India and Norway – withholding tax rates reduced
24 March 2007
Report on Attribution of Profits to PEs released
24 February 2007
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
24 February 2007
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
24 February 2007
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
24 February 2007
Amendments to domestic rules on avoiding double taxation (unilateral relief)
24 February 2007
Time limits for going to court for tax paid in error – reclaim of Norwegian dividend tax
15 January 2007
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
15 January 2007
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
15 January 2007
Helicopter is large enough to be a PE
17 December 2006
Amendments to CFC rules
17 December 2006
Protocol to treaty between Norway and Austria enters into force
17 December 2006
Budget for 2007 – details
12 November 2006
Treaty between Norway and Australia
12 November 2006
Treaty between Australia and Norway – details
12 September 2006
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
13 August 2006
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
13 August 2006
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
13 August 2006
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
13 August 2006
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
13 August 2006
Protocol to treaty between Austria and Norway – details
14 May 2006
Protocol between Norway and Austria signed
16 March 2006
Details of the new Czech Republic-Norway income tax treaty, signed on 19 October 2004, have become available. The treaty entered into force on 9 September 2005 and will generally apply from 1 January 2006. From this date, the new treaty will generally replace the Norway-former Czechoslovakia income and capital tax treaty and protocol of 27 June 1979 in respect of relations between Norway and the Czech Republic. The treaty was concluded in the English language. The treaty generally follows the OECD Model Convention and is probably one of the first treaties to contain the text of the Exchange of Information article (Art. 25) in the form included in the 2005 OECD Model update. It should also be noted that the treaty deals with mutual assistance in the collection of taxes between the Czech Republic and Norway (Art. 26).
9 November 2005
The new income tax treaty between Norway-Czech Republic, signed on 19 October 2004, entered into force on 31 August 2005. The treaty generally applies from 1 January 2006. From this date, the new treaty generally replaces the Norway-former Czechoslovakia income and capital tax treaty and protocol of 27 June 1979 in relations between Norway and the Czech Republic.
16 October 2005
The government of Norway has submitted a new protocol to the Norway-Switzerland tax treaty to the parliament for ratification. Under the protocol, the rate of withholding tax for dividends will be reduced to nil for corporate shareholders holding 20% or more of the share capital of the distributing company. For other shareholders, the withholding tax rate will remain at 15%. A deadline of 3 years for reclaiming excessive withholding tax will be introduced by a new provision to the treaty.
9 June 2005