Norway: Certain UK and Dutch pension organisations eligible for tax exemption on dividends
Effective
1 January 2014
UK pension schemes and Dutch pension funds are eligible to benefit from withholding tax exemption on Norwegian dividend payments made as from tax year 2014.
This is due to amendments to the provisions of the respective Double Taxation Treaties (DTTs).
UK pension schemes
Eligible UK pension schemes are as defined in Article 3 paragraph 1 of the DTT and include any UK pension scheme that:
- Is a resident of the United Kingdom; and
- Operates to administer or provide pension or retirement benefits or to earn income for the benefit of one or more such arrangements; and
- Is generally exempt from income taxation; and
- Is a pension scheme (other than a social security scheme) registered under Part 4 of the Finance Act 2004, including pension funds or pension schemes arranged through insurance companies and unit trusts where the unit holders are exclusively pension schemes.
Dutch pension funds
Eligible Dutch pension funds are those as defined in Article 3 paragraph 1 of the DTT and include any Dutch pension fund that:
- Is a resident of The Netherlands; and
- Operated principally to administer or provide pensions; and
- Is recognised and supervised by the Central Bank of the Netherlands (De Nederlandse Bank) and the Netherlands Authority for the Financial Markets (Autoriteit Financiële Markten) according to the regulations of the Pensions Act (Pensioenwet).
Impact on customers
The above-mentioned UK and Dutch pension organisations will be eligible for full exemption from withholding tax on dividend distributions paid, as from tax year 2014, on Norwegian equities.
Exemption at source is currently not available via Clearstream Banking1 but eligible UK and Dutch pension organisations may, provided that all the requested documentation is submitted to Clearstream Banking, obtain the benefit of the exemption via a standard refund application.
Important note:
To benefit from the exemption, the eligible UK or Dutch pension organisation must provide, in addition to the customary standard refund required documentation, a certificate of residence confirming that it meets all the DTT requirements for tax exemption.
Further information
For further information, customers may contact the Clearstream Banking Tax Help Desk on:
| Luxembourg | Frankfurt | Singapore | |
| Email: | tax@clearstream.com | tax@clearstream.com | tax@clearstream.com |
| Telephone: | +352-243-32835 | +49-(0) 69-2 11-1 3821 | +65-6597-1665 |
| Fax: | +352-243-632835 | +49-(0) 69-2 11-61 3821 |
or Clearstream Banking Customer Service or their Relationship Officer.
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1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500 (CBF) and Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Register of Commerce and Companies under number B-9248 (CBL).
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