Orbitax

Norway Tax News

EU Commission requests Italy to implement the Interest and Royalties Directive correctly

24 February 2007

Report on Attribution of Profits to PEs released

24 February 2007

Amendments to domestic rules on avoiding double taxation (unilateral relief)

24 February 2007

EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends

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 requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound 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

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

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