Norwegian withholding tax : relief at source now available

Launch of online tax filing system In 2017, the Norwegian tax authorities (COFTA) introduced ‘Altinn’, a new web portal designed to enable electronic filing and exchange between tax payers and the tax administration. The use of this portal is COFTA’s and Globe Refund’s preferred method for filing withholding tax reclaims. Upon submission, a tracking reference for the claim will be issued. However, since the process is web-based, Globe Refund will continue to require hard copies of documents in order to be able to perform a reliable filing and provide original documentation if requested by the tax authorities. Relief at source — securities account with reduced or 0% tax rate Shareholders may obtain securities accounts with a reduced or 0% tax rate. To benefit from such accounts, the shareholders should either submit to the VPS account operator/custodian a refund decision from the prior years or obtain an advanced approval from COFTA. Other documents such as a certificate of residence (COR) and a statement that the recipient of the dividends is the beneficial owner must be provided and renewed every three years. Application for advanced approval from COFTA To obtain advanced approval, shareholders should file an application containing key elements such as:

• Documentation that the conditions are met to benefit from a reduced or 0% tax rate
• Full name and address of the beneficial owner
• For application under a Double Tax treaty (DTT), a COR issued by the tax authorities of the country of which the shareholders claim to be resident with reference to the DTT with Norway; certificate to be issued within six months prior to the application
• For application under the Norwegian exemption method, a detailed description of the foreign entity's legal structure, comparability analysis and COR to be provided.

Updated obligations for existing nominee account operators Entities allowed to hold nominee accounts with a reduced or 0% tax rate will have to renew this authorization by filing a new application with COFTA as existing accounts were discontinued as of 1 January 2018. In the absence of a renewed application, each VPS account shall be considered as a 25% withholding tax account. Globe Refund recommendation To ensure a beneficial taxation of your investment funds in Norway, the relief at source documentation should be reviewed and updated if relevant. Globe Refund can help put the necessary procedures in place.   Contact us for more information   Stanislas Conte, CEO