News Share

The Tax Hub

Daily Tax Newsletter

Switzerland; Norway

21 December 2009

Responsive image

Protocol to treaty between Switzerland and Norway – details

Details of the amending protocol to the income and capital tax treaty of 7 September 1987 as amended by the 2005 protocol between Switzerland and Norway, signed on 31 August 2009, have become available. The treaty was concluded in the German, Norwegian and English languages. In the case of divergence, the English text prevails.

Compliance with the OECD standard by extending administrative assistance in line with the standard set in Art. 26 of OECD Model Tax Convention was the motivation for the protocol;

Information exchange based on Art. 26 can be requested only after the contracting state has exhausted all regular information sources available under the internal taxation procedure. Furthermore, Art. 26 does not commit the contracting states to spontaneous or automatic information exchange and does not include "fishing expeditions", i.e. measures aimed only at the simple collection of pieces of evidence. The received information can be used for purposes other than those mentioned in the protocol (e.g. the enforcement or prosecution in respect of taxes covered by the treaty) provided that the use of information is allowed by the laws of both states and the competent authority of the supplying state authorizes such use.

In addition, an amendment was made to Art. 10. The general maximum withholding tax rate on dividends will remain at 15%. However, the dividends shall be exempt from tax if paid to a company which holds directly at least 10% (previously 20%) of the capital of the company paying the dividends.

Furthermore, Art. 18 as amended by the protocol, gives the source state a taxing right regarding pensions paid to a resident of the other contracting state limited to a maximum of 15% of the gross amount of such pensions.

Powerful Tax Tools


FX Rates

Global FX Rates including Tax Year Average FX Rates and Spot Rates for all Reporting Currencies.


Corporate Tax Rates

Corporate tax rates, surtaxes, and effective tax rates for the current year, as well as historical rates and approved future rates.


Country Analysis

Detailed tax guidance for companies doing business in over 100 countries, including summaries and snapshots of key tax facts and issues.


Cross Border Tax Calculator

Calculate total tax costs and benefits of a cross border transaction including withholding tax, participation exemption and foreign tax credit rules.


Cross Border Tax Rates

Provides Domestic, treaty and EU cross border tax rates for over 5,000 country combinations for 9 different payment streams.



Complete overview of the OECD BEPS Project, including daily BEPS news, country adoption of BEPS measures, and an overview of the 15 BEPS Actions.


Tax Calendar

Customizable calendar tool that tracks corporate income tax, value added tax and transfer pricing obligations by country or entity.


Tax Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.


Worldwide Tax Treaties

Repository including thousands of tax treaties (in English), OECD, UN and US Models, relevant EU Directives, Technical Explanations, and more.


Worldwide Tax Planner

Calculates the worldwide tax cost of what-if scenarios based on legal entity structure, taxable income, and cross border transactions.


Certified Rates Report

Customizable Certified Rates Report providing updated corporate and withholding tax rates at the end of each month for over 100 countries.


Withholding Tax Minimizer

Enables quick calculation of tax costs and benefits of cross border transactions considering all possible transaction combinations and optimal routes.


VAT Rates

Provides value added tax (VAT) rates, goods and services tax (GST) rates and other indirect tax rates for over 100 countries.


NOL Calculator

Country specific calculator to determine how net operating losses can be utilized in carryback and carryforward years.


Transfer Pricing Calculator

Calculates TP ratios under various TP methods and calculates the difference between target ratios and actual ratios.


Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

Compare Forms

English translations of key tax forms for over 80 countries, including tax return forms, treaty benefit forms, withholding tax forms, and more.

We’re here to help

We’re here to answer any questions you have about the Orbitax products and services.

Send us a message

Who’s behind Orbitax?

We’re committed to providing high value, low cost tax research and management solutions.

Learn More