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Norway and US agree qualifying RICs aren't restricted from Double Tax Treaty benefits

17 December 2024

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Tax Alerts, Treaties, National/Federal Taxation, Treaties, Global

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United States, Norway

On 6 November 2024, the US and Norway signed a Competent Authorities Agreement (CAA) allowing qualifying Regulated Investment Companies (RICs) to claim treaty benefits under the US-Norway Double Tax Treaty, including a reduction of dividend withholding tax to 15%.The CAA aligns with a recent Norwegian Tax Appeal Board decision, which determined that RICs are eligible for treaty benefits, potentially allowing for retroactive refund claims for dividend withholding tax paid in prior years, within the five-year statute of limitations. On 6 November 2024, the competent authorities in the United States (US) and Norway signed a Competent Authorities Agreement (CAA), agreeing that qualifying...