Dividend withholding limits: source-state tax capped for qualifying corporate owners; PE connection shifts taxation to business-profit rules. Under the Norway DTAA, dividends paid by a resident company may be taxed in the recipient's residence State, but the source State may also tax such dividends subject to capped withholding when the recipient is the beneficial owner-reduced where a corporate beneficial owner holds a qualifying direct stake and dividends arise from a new contribution, and a higher cap otherwise. Dividends connected with a permanent establishment or fixed base are taxed under business profits or independent personal service rules, and the Convention prevents the other State from taxing such dividends or undistributed profits except in specified resident or effectively connected cases.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Dividend withholding limits: source-state tax capped for qualifying corporate owners; PE connection shifts taxation to business-profit rules.
Under the Norway DTAA, dividends paid by a resident company may be taxed in the recipient's residence State, but the source State may also tax such dividends subject to capped withholding when the recipient is the beneficial owner-reduced where a corporate beneficial owner holds a qualifying direct stake and dividends arise from a new contribution, and a higher cap otherwise. Dividends connected with a permanent establishment or fixed base are taxed under business profits or independent personal service rules, and the Convention prevents the other State from taxing such dividends or undistributed profits except in specified resident or effectively connected cases.
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