Indirect Tax
Agnete Haugerud
Per Oskar Tobiassen
Cecilie Asprong Dyrnes
Øystein Arff Gulseth
Law
Kjeld Arne Thomassen
Bergen
EY
Thormølens gate 53D
P.O. Box 6163, Bedriftssenter NO-5892 Bergen Norway
Mobile: +47 982-06-318
Email: agnete.haugerud@no.ey.com
Mobile: +47 982-06-269
Email: per.oskar.tobiassen@no.ey.com
Mobile: +47 982-94-516
Email: cecilie.dyrnes@no.ey.com
Mobile: +47 982-06-387
Email: oystein.arff.gulseth@no.ey.com
Mobile: +47 907-23-766
Email: kjeld.arne.thomassen@no.ey.com
+47 55-21-30-00
Fax: +47 55-21-30-03
Business Tax Services and Business Tax Advisory
Tordis Borgen
Indirect Tax
Gaute Ebeltoft
Law
Astrid Foyn-Bruun
Stavanger
EY
Vassbotnen 11A
P.O. Box 8015 N-4068 Stavanger Norway
Mobile: +47 982-06-451
Email: tordis.borgen@no.ey.com
Mobile: +47 982-06-476
Email: gaute.ebeltoft@no.ey.com
Mobile: +47 415-12-989
Email: astrid.foyn-bruun@no.ey.com
+47 51-70-66-00
Fax: +47 51-70-66-01
International Tax and Transaction Services — International Corporate Tax Advisory and Petroleum Tax Services
Eivind Galta
Mobile: +47 902-71-142
Email: eivind.galta@no.ey.com
Business Tax Services and Business Tax Advisory
Harry Veum
People Advisory Services
Helen Totland
Indirect Tax
Kari Lise Ingwardo
Law
Paal Baarsrud Fagerli
Mobile: +47 976-13-311
Email: harry.veum@no.ey.com
Mobile: +47 982-06-652
Email: helen.totland@no.ey.com
Mobile: +47 416-92-160
Email: kari.lise.ingwardo@no.ey.com
Mobile: +47 924-35-376
Email: paal.fagerli@no.ey.com
Unless otherwise indicated, the rates and thresholds stated in the chapter are applicable as of 1 January 2024.
A. At a glance
Net Operating Losses (Years)
Carryforward
(a) A 25% rate applies to companies in the financial sector (see Section B).
(b) This tax applies to dividends paid to nonresident shareholders. Dividends paid to corporate shareholders that are tax residents and genuinely established in Member States of the European Economic Area (EEA) (including the European Union [EU], Iceland and Liechtenstein) are exempt from withholding tax.
(c) A 15% withholding tax on interest, royalties and certain lease payments to related entities resident in a low-tax jurisdiction has been introduced. The rules entered into force on 1 July 2021 for interest and royalties and on 1 October 2021 for certain lease payments. The withholding tax may be reduced or exempt under the provisions of a tax treaty entered into by Norway or when the recipient is a company that is actually established and carrying on genuine economic activities within the EEA. For the purpose of the rules, a company is considered a “related party” if the payer and the recipient are directly or indirectly under the same ownership and control by at least 50%. The term “low-tax jurisdiction” is to be interpreted in line with the controlled foreign company rules (see Section E).
(d) See Section C.
B. Taxes on corporate income and gains
Corporate income tax. In general, resident companies are subject to corporate income tax on worldwide income. However, profits and losses on upstream petroleum activities in other jurisdictions are exempt from Norwegian taxation. Nonresident companies are subject to corporate income tax on income attributable to Norwegian business operations. Effective from the 2024 income year, foreign companies operating in mineral exploitation, renewable energy or carbon management within the Norwegian 200-nautical-mile zone and on the Norwegian continental shelf are subject to tax.
A company is tax resident in Norway if it is legally incorporated according to Norwegian corporate law or if its effective management is carried out in Norway.
Rates of corporate tax. The corporate tax rate is currently 22%.
In addition to the general income tax of 22%, a special petroleum tax of 56% applies to income from oil and gas production and from pipeline transportation. A special power production tax of 45% applies on top of the general income tax of 22% for the generation of hydroelectric power.
Effective from 1 January 2024, a special resource rent tax at an effective rate of 25% applies to onshore wind farms comprising of more than five turbines, or with a total capacity of one megawatt or more.
Effective from the 2023 income year, a similar resource rent tax of 25%, applies to aquaculture income exceeding a tax-free allowance (standard deduction) determined by the parliament on an annual basis. For the 2023 income year, the tax-free allowance is set to NOK70 million.
For companies in the financial sector, a 25% rate applies if they are within the scope of the financial tax rules (see Financial tax).
Qualifying shipping companies may elect to be taxed under the Norwegian tonnage tax regime instead of the ordinary tax regime. Under the tonnage tax regime, profits derived from qualifying shipping activities are exempt from income tax. However, companies electing the shipping tax regime must pay an insignificant tonnage excise tax. Financial income derived by shipping companies is taxed at a rate of 22%. Breach of the requirements under the regime generally leads to forced exit from the regime. A tax committee has proposed to abolish the tonnage tax regime in its report presented to the government on 19 December 2022, but it is uncertain whether the government will move forward with this proposal.
Norway has adopted Pillar Two measures; see the BEPS 2.0 –Pillar Two Developments Tracker
Financial tax. A financial tax for companies in the financial sector was introduced from 1 January 2017. The main purpose of the financial tax is to serve as a form of substitute tax for financial businesses that are value-added tax (VAT)-exempt (that is, they benefit from the Norwegian VAT exemption for the sale and mediation of financial services). The financial tax consists of the following two elements:
• The application of a 25% rate on the income of companies covered by the financial tax, instead of the 22% rate, which applies to companies in all other sectors
• A 5% tax on wage costs
The main rule is that all companies that conduct activities that are covered by Group K “Financial and insurance activities” (Codes 64-66) in SN2007 (the European system NACE rev. 2) are subject to the financial tax. These types of activities are referred to as financial activities. The financial tax applies only to companies with employees.
The following businesses are typically subject to the financial tax:
• Businesses engaged in banking
• Businesses engaged in insurance (both life and general insurance)
• Securities funds
• Investment companies
• Holding companies
• Pension funds
• Businesses performing services related to finance business, including administration of financial markets and mediation of securities
The 5% tax on wage cost is calculated based on the yearly payments to all of the company’s employees who perform financial
security or a guarantee for the outstanding tax payable. No deferral of the tax is available for intangible assets and inventory.
Administration. The annual tax return is due on 31 May for accounting years ending in the preceding calendar year and must be submitted electronically. Assessments are made in the year in which the return is submitted (not later than 1 December). Tax is paid in three installments. The first two are paid on 15 February and 15 April in the year after the income year, respectively, each based on one-half of the tax due from the previous assessment. The last installment represents the difference between the tax paid and the tax due, and is payable three weeks after the issuance of the assessment. Interest is charged on residual tax.
Dividends. An exemption regime with respect to dividends on shares is available to Norwegian companies if the distribution is not deductible for tax purposes at the level of the distributing entity. However, the 100% tax exemption is limited to 97% if the recipient of the dividends does not hold more than 90% of the shares in the distributing company and a corresponding part of the votes that may be given at the general meeting (that is, the companies do not constitute a tax group of companies). In such cases, the remaining 3% of the dividends is subject to 22% taxation, which results in an effective tax rate of 0.66%.
The tax exemption applies regardless of the ownership participation or holding period if the payer of the dividends is a resident in an EEA Member State. However, if the EEA country is regarded as a low-tax jurisdiction, the EEA resident company needs to qualify as actually established and carrying out genuine economic activities in its home country.
For non-EEA resident companies, the exemption does not apply to dividends paid by the following companies:
• Companies resident in low-tax jurisdictions as defined in the Norwegian tax law regarding CFCs (see Section E)
• Other companies of which the recipient of the dividends has not held at least 10% of the capital and the votes of the payer for a period of more than two years that includes the distribution date
Dividends paid to nonresident shareholders are subject to a 25% withholding tax. The withholding tax rate may be reduced by tax treaties. Dividends distributed by Norwegian companies to corporate shareholders resident in EEA Member States are exempt from withholding tax. This exemption applies regardless of the ownership participation or holding period. However, a condition for the exemption is that the EEA resident company be actually established and carrying out genuine economic activities in its home country.
Foreign tax relief. A tax credit is allowed for foreign tax paid by Norwegian companies, but it is limited to the proportion of the Norwegian tax that is levied on foreign-source income. Separate limitations must be calculated according to the Norwegian tax treatment of the following two different categories of foreignsource income:
• Income derived from low-tax jurisdictions and income taxable under the CFC rules
• Other foreign-source income
For dividend income taxable in Norway (that is, dividends that are not tax-exempt under the exemption regime), Norwegian companies holding at least 10% of the share capital and the voting rights of a foreign company for a period of more than two years that includes the distribution date may also claim a tax credit for the underlying foreign corporate tax paid by the foreign company, provided the Norwegian company includes an amount equal to the tax credit in taxable income. In addition, the credit is also available for tax paid by a second-tier subsidiary, provided that the Norwegian parent indirectly holds at least 25% of the second-tier subsidiary and that the second-tier subsidiary is a resident of the same country as the first-tier subsidiary. The regime also applies to dividends paid out of profits that have been retained by the first- or second-tier subsidiary for up to four years after the year the profits were earned. The tax credit applies only to tax paid to the country where the first- and second-tier subsidiaries are resident.
C. Determination of taxable income
General. In calculating taxable income, book income shown in the annual financial statements (which must be prepared in accordance with generally accepted accounting principles) is used as a starting point. However, the timing of income taxation is based on the realization principle. Consequently, the basic rules are that an income is taxable in the year in which the recipient obtains an unconditional right to receive the income, and an expense is deductible in the year in which the payer incurs an unconditional obligation to pay the expense. In general, all expenses, except gifts and entertainment expenses, are deductible.
Inventory. Inventory is valued at cost, which must be determined on a first-in, first-out (FIFO) basis.
Depreciation. Depreciation on fixed assets must be calculated using the declining-balance method at any rate up to a given maximum. Fixed assets (with a cost of more than NOK30,000 and with a useful life of at least three years) are allocated to one of the following 10 different groups.
A Office equipment and similar items
B Acquired goodwill
C Specified vehicles Trailers, trucks and buses
Commercial vehicles, taxis and vehicles for the transportation of disabled persons
D Cars, tractors, other movable machines, other machines, equipment, instruments, furniture, fixtures and similar items
E Ships, vessels, drilling rigs and similar items
F Aircraft and helicopters
G Installations for transmission and distribution of electric power, electronic equipment in power stations and such production equipment used in other industries
H Industrial buildings and industrial installations, hotels, rooming houses, restaurants and certain other structures
Useful life of 20 years or more 4 Useful life of less than 20 years 10 Livestock buildings in the agricultural sector 6 I Office buildings 2 J Technical installations in buildings 10
Assets in groups A, B, C and D are depreciated as whole units, while assets in groups E, F, G, H, I and J are depreciated individually.
If fixed assets in groups A, B, C and D are sold, the proceeds reduce the balance of the group of assets and consequently the basis for depreciation. If a negative balance results within groups A, C or D, part of the negative balance must be included in income. In general, the amount included in income is determined by multiplying the negative balance by the depreciation rate for the group. However, if the negative balance is less than NOK30,000, the entire negative balance must be included in taxable income.
A negative balance in one of the other groups (B, E, F, G, H, I and J) must be included in a gains and losses account. Twenty percent of a positive balance in this account must be included annually in taxable income.
Relief for losses. A company holding more than 90% of the shares in a subsidiary may form a group for tax purposes. To consolidate taxable income in a tax group, a company with net profits may transfer those profits to a loss-making company. The profits are required to be actually transferred between the group companies. Companies covered by the financial tax (see Financial tax in Section B) may only deduct 22/25 of intragroup contributions to companies not covered by the financial tax.
Effective from the 2021 income year, Norwegian companies may grant tax-deductible group contributions to subsidiaries that are resident in an EEA country, provided that certain conditions are fulfilled. The group contribution must cover a final loss in the subsidiary, in line with the principles established under EU case law.
Alternatively, losses may be carried forward indefinitely. Losses can only be carried back when a line of business has been terminated. Losses may be carried back to offset profits of the preceding two years.
D. Other significant taxes
The following table summarizes other significant taxes.
Nature of tax Rate (%)
Value-added tax, on any supply of goods and services, other than zero-rated (0%) and exempt (without credit) supplies, in Norway
Nature of tax
Passenger transportation, cultural events and certain other supplies
Social security contributions, on all taxable salaries, wages and allowances, and on certain fringe benefits; paid by Employer
E. Miscellaneous matters
Anti-avoidance legislation. According to a general anti-avoidance provision in Norwegian legislation, tax authorities may disregard a transaction if its main purpose is to obtain a tax benefit and, after an overall assessment, it is determined that the transaction cannot be used as the basis for taxation. The determination of whether the main purpose is to obtain a tax benefit is dependent on an objective assessment (that is, an assessment of what a hypothetical rational taxpayer would have done in a similar situation instead of the specific taxpayer).
In addition, Norwegian legislation has a specific anti-avoidance rule. If a company with a general tax position (that is, a tax position not connected to any specific asset or debt, such as a tax loss carryforward) is involved in a transaction in which the use of that tax position is the main objective of the transaction, the tax authorities may disallow such a tax position. This rule has a narrower scope, but a lower threshold for application, than the general anti-avoidance provision described above.
Foreign-exchange controls. Norway does not impose foreignexchange controls. However, foreign-exchange transactions must be carried out by approved foreign-exchange banks.
Debt-to-equity rules. Norway does not have statutory thincapitalization rules. Based on the arm’s-length principle (see Transfer pricing), the tax authorities may deny an interest deduction on a case-by-case basis if they find that the equity of the company is not sufficient (for example, the Norwegian debtor company is not able to meet its debt obligations). An allocation rule regulates the deductibility of interest expenses for income subject to petroleum tax.
Norway has interest limitation rules. Under these rules, interest payments that exceed 25% of tax earnings before interest, tax, depreciation and amortization (EBITDA), which is defined as “ordinary taxable income with tax depreciation and net interest expenses added back, are nondeductible (fixed ratio rule).”
These rules impose a general restriction on interest deductibility, which applies to corporations and transparent partnerships as well as Norwegian permanent establishments of foreign companies. The restriction applies to interest payments made in both domestic
and cross-border situations. With respect to companies that are not part of a group, only interest paid to related persons are covered by the fixed ratio rule. Companies that are part of a consolidated multinational group for financial accounting purposes or companies that can be part of such group (group companies) are subject to the fixed ratio rule on interest paid on both internal and external loans. Companies taxed under the tonnage tax regime and under the hydropower tax regime are also subject to the fixed ratio rule. However, entities subject to the Norwegian Petroleum Tax Act are not yet covered by the rules.
The fixed ratio rule applies only if net interest expenses exceed the threshold established by the law. For group companies, the threshold is NOK25 million, which is computed on a combined basis for all Norwegian entities in the global consolidated group. For companies that are not part of a group, the threshold is NOK5 million. If the applicable threshold is exceeded, all interest expenses must be assessed under the fixed ratio rule, including the first NOK25 million or NOK5 million.
There are two alternative equity escape rules that may apply to group companies if the threshold of NOK25 million is exceeded.
The first equity escape rule allows all interest expenses to be deducted if the Norwegian company can demonstrate that its adjusted equity over total assets ratio (equity ratio) is no more than two percentage units (points) lower than the equivalent equity ratio of the global group.
The second equity escape rule allows all interest expenses to be deducted if the combined Norwegian part of the group can demonstrate that its adjusted equity ratio is no more than two percentage units lower than the equivalent equity ratio of the global group.
Certain exceptions apply to interest expenses incurred by group companies on borrowing arrangements with related parties that are not part of the consolidated group. For such related-party interest, the equity escape rules do not apply and, if net interest expenses in the borrowing entity exceed NOK5 million, the net related-party interest can be deducted only to the extent both internal and external net interest expenses do not exceed 25% of tax EBITDA.
Under the rules, a related party is a person, company or entity if, at any point during the fiscal year, any of the following is true:
• It directly or indirectly controls at least 50% of the debtor.
• It is a company or entity of which the debtor directly or indirectly controls at least 50%.
• It is a company or entity that is at least 50% owned directly or indirectly by the same company or entity as the debtor.
Effective from the 2024 income year, net intra-group interest income is not included in the calculation of net interest expenses if the EBITDA rule between related parties applies to companies in a group. The provision will only have an impact on group companies that remit/owe interest expenses to related parties that are not part of the same group for the purpose of the interest limitation rules.
Companies that meet the following criteria for the relevant tax year are exempt from the documentation requirements:
• The real value of the controlled (intercompany) transactions is less than NOK10 million during the fiscal year.
• At the end of the relevant tax year, the intercompany loans, debts, guarantees and receivables amount to less than NOK25 million.
In addition, Norwegian entities belonging to a group of companies with less than 250 employees may be exempted from the abovementioned documentation requirements if the group has consolidated sales revenue of less than NOK400 million or a consolidated total balance of less than NOK350 million. The exemption does not apply if the Norwegian entity has controlled transactions with related parties located in countries from which Norwegian tax authorities cannot request exchange of information under a treaty. The exemption also does not apply to companies subject to tax under the Norwegian Petroleum Tax Act.
Country-by-Country Reporting. Norway has introduced Countryby-Country Reporting (CbCR) requirements that mainly follow OECD BEPS Action 13 requirements. The CbCR requirements apply to Norwegian entities that are part of a multinational group of companies with consolidated turnover exceeding NOK6.5 billion. Any Norwegian entity that is part of such group of companies must notify the Norwegian tax authorities about the reporting entity for the group in the annual tax return (Form RF-1028) concerning the reporting year, at the latest. The requirements are stated in Section 8-12 of the Tax Administration Act.
F. Treaty withholding tax rates
In Norway, there is a 15% withholding tax on interest, royalties and certain lease payments to related parties resident in a low-tax jurisdiction. For the purpose of the rules, a company is considered a “related party” if the payer and the recipient are directly or indirectly under the same ownership and control by at least 50%. The term “low-tax jurisdiction” is to be interpreted in line with the controlled foreign company rules (see Section E). The treaty rates listed below for interest and royalties apply from 1 January 2024, subject to the fulfillment of requirements (if any) established in each treaty.
Many treaties provide exemptions for dividend, interest and royalties paid to certain entities (for example, to the state, local authorities, the central bank, export credit institutions or with respect to sales on credit). Such exemptions are not considered in the table below.
10/15 (c) 12 (u) 3/5/10/15 (dd)
0/5/15 (n) 0/10 (v) 5
(o) 0
(d) 10
Belgium (a)(b) 0/5/15 (d) 0/10 (uu) 0
(d)
Canada (b) 5/15 (d)
0/10 (ee)
Chile 5/15 (c) 4/5/15 (w) 2/10 (ff) China
Cyprus (a) 0/15 (d)
Czech Republic (a)(e) 0/15 (d)
Denmark (a) (Nordic Treaty) 0/15 (d)
(b) 15
Estonia (a) 5/15 (c)
Faroe Islands (Nordic Treaty) 0/15 (d)
Finland (a) (Nordic Treaty) 0/15 (d)
(i)
(c)
(d)
(c)
Hungary (a)
Iceland (a) (Nordic Treaty)
(gg)
(hh)
(ii)
(d)
Ireland (a) 5/15 (d)
(b) 5/15 (g)
Korea (South) (b) 15 15 10/15 (ll)
Latvia (a)(b) 5/15 (c) 10 0/5/10 (mm)
Lithuania (a) 5/15 (c) 10 0/5/10 (mm)
Luxembourg (a) 5/15 (c) 0 0 Malawi 5/15 (d) 10
Malaysia (b) 0
Malta (a) 0/15 (r)
0/15 (c) 10/15 (x)
(f) 15
Nepal 5/10/15 (h) 10/15 (y) 15 (kk) Netherlands (a) 0/15 (d) 0
(b)
(c)
(c)
(d)
(w) The 5% rate applies to interest derived from bonds or securities that are regularly and substantially traded on a recognized securities market. The 4% rate applies if the beneficial owner is one of the following:
• A bank
• An insurance company
• An enterprise substantially deriving its gross income from the active and regular conduct of a lending or finance business involving transactions with unrelated persons if the enterprise is unrelated to the payer of the interest
• An enterprise that sold machinery or equipment if interest is paid with respect to indebtedness that arises as part of the sale on credit of such machinery or equipment
• Any other enterprise, provided that in the three tax years preceding the tax year in which the interest is paid, the enterprise derives more than 50% of its liabilities from the issuance of bonds in the financial markets or from the taking of deposits at interest, and more than 50% of the assets of the enterprise consist of debt-claims against unrelated persons
The 15% rate applies in all other cases.
(x) The 10% rate applies to interest paid to banks.
(y) The 10% rate applies to interest paid to banks carrying on bona fide banking business.
(z) The 0% rate applies to interest on certain qualifying loans.
(aa) The 10% rate applies to interest paid to financial institutions (including insurance companies). A most-favored-nation clause may apply with respect to interest payments.
(bb) The 5% rate applies to certain credit institutions providing export credits or a government pension or social security fund. The 10% rate applies to interest paid to banks. The 15% rate applies in all other cases.
(cc) The 5% rate applies to interest paid to banks.
(dd) The 3% rate applies to news-related royalties. The 5% rate applies to copyright royalties other than royalties related to films or tapes. The 10% rate applies to patents, trademarks, know-how, certain lease-related royalties and technical assistance. The 15% rate applies in all other cases. A most-favorednation clause may apply with respect to royalty payments.
(ee) The 0% rate applies to copyright royalties (excluding films), computer software, patents and know-how.
(ff) The royalties’ rates under the treaty are 5% for equipment leasing and 15% in all other cases. However, as a result of a most-favored-nation clause, the rates are reduced to 2% for equipment leasing and 10% in all other cases.
(gg) The 0% rate applies to copyrights of literary, artistic or scientific works except for computer software and including cinematographic films, and films or tapes for television or radio broadcasting. The 5% rate applies to industrial, commercial or scientific equipment. The 10% rate applies to patents, trademarks, designs or models, plans, secret formulas or processes and computer software, or for information concerning industrial, commercial or scientific experience.
(hh) The reduced rate does not apply to royalties with respect to cinematographic films.
(ii) The rates for royalties under the treaty are 5% for equipment rentals and 10% in all other cases. However, as a result of a most-favored-nation clause, royalties are exempt from withholding tax.
(jj) The 10% rate applies for the use of any patents, trademarks, designs or models, plans, secret formulas or processes, and for the supply of commercial, industrial or scientific equipment or information. The 15% rate applies for the use of, or the right to use, copyrights of literary, artistic or scientific works, including cinematographic films or films or tapes for radio or television broadcasting.
(kk) A most-favored-nation clause may apply with respect to royalties.
(ll) The 10% rate applies for the use of any patents, trademarks, designs or models, plans, secret formulas or processes, and for the supply of commercial, industrial or scientific equipment or information. The 15% rate applies for the use of, or the right to use copyrights of literary, artistic or scientific works, including cinematographic films.
(mm) The 5% rate applies to royalties paid for the use of industrial, commercial or scientific equipment. The 10% rate applies to all other cases. A most-favorednation clause may apply with respect to royalties, reducing the rate to 0%.
(nn) The 5% rate applies to royalties paid for the use of, or the right to use copyrights of literary, artistic or scientific works, including cinematographic films or films or tapes used for radio or television broadcasting. The 10% rate applies to royalties paid for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, or for the use of, or
As a result of the OECD’s MLI, Norway has signed updated treaties with 28 jurisdictions (Argentina, Australia, Bulgaria, Chile, China Mainland, Cyprus, Czech Republic, Estonia, Georgia, Greece, India, Ireland, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Netherlands, Poland, Portugal, Romania, Russia, Serbia, Slovenia, South Africa, Türkiye and the United Kingdom). The MLI agreement that Norway signed with China Mainland entered into force on 1 September 2022. The MLI agreement that Norway signed with Bulgaria and South Africa entered both into force 1 January 2023. The MLI agreements with Argentina and Türkiye are not yet in force.
Norway has entered into exchange-of-information tax treaties with Andorra, Anguilla, Antigua and Barbuda, Aruba, Bahamas, Bahrain, Belize, Bermuda, Botswana, British Virgin Islands, Brunei Darussalam, Cayman Islands, Cook Islands, Costa Rica, Denmark (Nordic Treaty), Dominica, Faroe Islands (Nordic Treaty), Finland (Nordic Treaty), Gibraltar, Grenada, Guernsey, the Hong Kong SAR, Iceland (Nordic Treaty), Isle of Man, Jersey, Liberia, Lichtenstein, the Macau SAR, Marshall Islands, Mauritius, Monaco, Montserrat, Niue, Panama, Samoa, San Marino, Seychelles, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, the Turks and Caicos Islands, the United Arab Emirates, the United States, Uruguay and Vanuatu.
In addition, Norway signed an exchange-of-information tax treaty with Guatemala on 15 May 2012, but the agreement is not yet in force.