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Protocol to treaty between Germany and Norway – details

12 November 2013

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Treaty Development

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Germany; Norway

Details of the amending protocol to the Germany - Norway Income and Capital Tax Agreement (1991), signed on 24 June 2013, have become available. The protocol was concluded in the German and Norwegian languages, each text having equal authenticity. The most important amendments contained in the protocol are: -   introduction of a new article 7 on business profits in line with article 7 of the OECD Model (2010); -   a withholding tax rate of 0% on dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 25% of the capital of...