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Netherlands Updates Norway DTA

Tuesday, 07 May 2013   (0 Comments)
Posted by: Author: Ulrika Lomas
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Source: Ulrika Lomas (, Brussels)

The Dutch Finance Ministry has announced that the existing tax treaty between the Netherlands and Norway has now been amended and updated.

A protocol revising the original agreement was signed in Oslo on April 23, 2013. The changes made to the 1990 treaty are intended to modernize certain aspects of the text.

The protocol provides for a reduction in the withholding tax rate levied on dividends from pension funds, from 15% to 0%. The taxing rights for profits earned from the provision of services are accorded to the country in which the services are carried out, proving the activity is undertaken for a period of at least six months.

Furthermore, the taxing rights for pensions, annuities, and social security pensions and benefits will, in future, reside with the source state, namely the state in which pensions and fiscal benefits are accrued.

In the case of a double taxation dispute, an arbitration committee will be set up to resolve the issue if the authorities of both treaty states fail to reach an agreement within two years.

Commenting, Dutch Financial State Secretary Frans Weekers highlighted the fact that the protocol will serve to significantly improve the investment climate. This is good news for Dutch companies planning to invest in Norway, and good news for Norwegian businesses intending to invest in the Netherlands, Weekers emphasized.



Section 240A of the Tax Administration Act, 2011 (as amended) requires that all tax practitioners register with a recognized controlling body before 1 July 2013. It is a criminal offense to not register with both a recognized controlling body and SARS.

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