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Fund Taxation Alert 2017-05

Fund Taxation Alert 2017-05

Norway: change in statute of limitations



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Norway: change in statute of limitations

As of 1 January 2017, the Norwegian statute of limitations has been extended to 5 years for the filing of withholding tax (“WHT”) reclaims.


Until recently, two statute of limitation periods were applied with respect to WHT reclaims in Norway: from the administrative practice’s point of view, the time limitation period of 3 years was applied, but the legal time limitation period of 1 year also existed. These periods were calculated as of 1 January of the year following the dividend distribution.

Current treatment

From January 2017 onwards, WHT reclaims should be filed within the new 5-year limitation period. The new time limitation period begins after the end of the assessment year during which the dividend payment has taken place, based on the Norwegian Tax Administration Act.

Under the new legislation, claims concerning WHT suffered during years 2012 to 2016 can be filed until 31 December 2017. For instance, if the dividend payment day is 14 February 2012, the new 5-year period started on 1 January 2013 and ends on 31 December 2017.


Any tax advice in this communication is not intended or written by KPMG to be used, and cannot be used, by a client or any other person or entity for the purpose of (i) avoiding penalties that may be imposed on any taxpayer or (ii) promoting, marketing, or recommending to another party any matters addressed herein.

The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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