Proposal for withholding tax on interest payments limited to related companies

The Norwegian Ministry of Finance has sent a draft for legislation on withholding tax on interests and royalties, etc. on a public consultation.

The withholding tax on interests is proposed for interest payments to related companies in low-tax countries. The withholding tax is meant to supplement the Norwegian interest limitation rule that restrains multinational group’s ability to reduce corporate income tax by excessive debt financing of Norwegian subsidiaries.

The proposal means that Norwegian bonds and certificates in the global capital market will not be covered by the withholding tax. This is good news as the tax committee suggested that the withholding tax should be imposed generally, and not be restricted to interest payments to related companies.

The consultation deadline is 27 May 2020. You can find the proposal here