News Share

The Tax Hub

Daily Tax Newsletter

Norway-Cyprus

23 September 2014

Responsive image

Tax Treaty between Norway and Cyprus has Entered into Force

According to a recent update published by the Norwegian Ministry of Finance, the new income tax treaty between Norway and Cyprus entered into force on 8 July 2014. The treaty, signed 24 February 2014, will replace the 1951 treaty between the two countries as extended by the 1955 exchange of notes.

Taxes Covered

The treaty applies to the following Norwegian taxes:

  • National tax on income
  • Municipal tax on income
  • County municipal tax on income
  • National tax relating to income from the exploration for and the exploitation of submarine petroleum resources and activities and related work, including pipeline transport of petroleum produced
  • National tax on remuneration to non-resident artistes

The treaty applies to the following Cyprus taxes

  • Income tax
  • Corporate income tax
  • Special contribution for the Defense of the Republic
  • Capital gains tax

Residence

If a company is a resident of both states, it will be deemed to be a resident of the State in which its effective management is located for treaty purposes. If the competent authorities cannot reach mutual agreement in regard to a taxpayer's residence, the taxpayer will not be considered a resident of either State nor eligible for the treaty benefits aside from those covered in Article 22 Elimination of Double Taxation, Article 23 Non-Discrimination, and Article 24 Mutual Agreement Procedure.

Service PE

A service PE will be deemed constituted when an enterprise from one Contracting State furnishes services in the other State through one or more individuals present in that other State for an aggregate period of 183 days or more in a 12 month period.

Withholding Tax Rates

  • Dividends - 0% if the beneficial owner is a company directly holding at least 10% of the paying company's capital, otherwise 15%
  • Interest - 0%
  • Royalties - 0%

Double Taxation Relief

Both countries apply the credit method for the elimination of double taxation.

MFN Provision

A protocol to the treaty, signed the same date, includes the provision that if Norway enters into an agreement with any EEA or EU Member State that provides for a lower withholding tax rate on dividends, then an amendment should be made to the Norway-Cyprus treaty to provide such lower rate.

Entry into Effect

The treaty applies from 1 January 2015. However, Article 26 Assistance in Collection will not apply in the case of Cyprus until written notice is provided by Cyprus to Norway that confirms that Cyprus is able to provide such assistance.

Once effective, the treaty replaces the 1951 treaty between the two countries as extended by the 1955 exchange of notes.

Powerful Tax Tools

NEW

FX Rates

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

NEW

Corporate Tax Rates

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

NEW

Country Analysis

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

NEW

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.

NEW

Cross Border Tax Rates

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

NEW

OECD BEPS Project

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

NEW

Tax Calendar

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

NEW

Tax Forms

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

NEW

Worldwide Tax Treaties

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

NEW

Worldwide Tax Planner

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

NEW

Certified Rates Report

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

NEW

Withholding Tax Minimizer

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

NEW

VAT Rates

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

NEW

NOL Calculator

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

NEW

Transfer Pricing Calculator

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

NEW

Individual Income Tax Rates

Individual tax rates for over 100 countries.

Play of the Day

FX Rates

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

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