Treaty detail
United Kingdom - Norway tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2013-03-14
Effective
2013-12-17
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The 2013 UK-Norway treaty applies a zero-percent rate for qualifying corporate parent-subsidiary cases and 15 percent more broadly. Article-level qualification rules and beneficial-ownership tests still apply.
Interest
Rate: 0%
The treaty generally eliminates source-country withholding on interest. Back-to-back, related-party, and beneficial-ownership tests still determine whether a particular payment qualifies.
Royalties
Rate: 0%
The treaty generally applies a zero rate to qualifying royalties across major categories. Article definitions control characterization for mixed contracts.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules apply where an agent habitually concludes contracts in the source country. Offshore-activity rules add a layer specific to the Norwegian continental shelf.
Other treaty flags
The UK-Norway treaty divides pension rights between source and residence depending on the type of payment. Article-level review is recommended for lump sums and government-service pensions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the prerequisite for every reduced rate or business-profit protection.
Residence under the 2013 UK-Norway treaty is especially important for dual-resident individuals and corporate groups. The tiebreaker rules in Article 4 resolve dual-residence questions and control entitlement to other treaty benefits.
Article 5
Permanent Establishment
Defines the threshold for source-country business taxation.
Article 5 follows the modern OECD pattern. The treaty includes specific rules for offshore activities relevant to the Norwegian continental shelf, which is a notable feature of the UK-Norway relationship.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief is the practical operating rule once the PE analysis confirms no source-country taxable presence. Attribution rules apply when a PE exists, including for activities on the Norwegian continental shelf.
Article 10
Dividends
Provides reduced and zero-percent rates for qualifying cross-border dividends.
The 2013 treaty modernized the dividend article. Qualifying parent-subsidiary cases can achieve a zero rate, with the 15 percent rate applying more broadly.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Interest payments between the UK and Norway commonly arise in intercompany financing and offshore-energy contexts. The zero rate is the headline, and the article-level tests apply.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article applies a zero rate to qualifying payments. The article-level definition controls how mixed contracts are characterized.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Norway tax treaties pageVerified 2026-05-20
- Norwegian Tax Administration (Skatteetaten) treaty listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.