The Norwegian Tax Appeal Board issued a decision 4 November 2020 (published 19 April 2021) in which tax treaty benefits for US Regulated Investment Companies (“RIC”) were discussed.
In contrast to previous practice the Tax Appeal Board found that RICs in principle were entitled to treaty benefits. However, the RIC in question failed to pass the Limitation of Benefit clause (LOB) in the tax treaty and was not granted a reduced withholding tax rate.
The decision could be of great interest to RICs investing in Norway.
Read details about the decision and possible effects here.
My name is Camilla Fingarsen and I work as a lawyer at PwC Tax and Legal Services. I have worked with tax since 2011, and I assist clients with general tax advice on Norwegian and international corporate tax law, including national and cross border restructurings.
Please feel free to contact me if you have any questions, comments or input.