Hong Kong and Norway sign income tax treaty to prevent double taxation and cap withholding taxes.
Hong Kong’s Inland Revenue Department announced, on 16 December 2025, that Hong Kong and Norway had signed a comprehensive income tax treaty aimed at preventing double taxation and promoting cross-border investment.
Under the agreement, the covered Hong Kong taxes are profits tax, salaries tax and property tax. On the Norwegian side, the treaty applies to the national tax on income, county municipal and municipal taxes on income, the national tax on income derived from the exploration and exploitation of submarine petroleum resources and related activities, including pipeline transportation of petroleum, as well as the national tax on remuneration paid to non-resident artistes.
The treaty sets out maximum withholding tax rates on cross-border payments between the two jurisdictions. Dividends may be taxed at 5% where the beneficial owner is a company that directly holds at least 25% of the capital of the paying company throughout a 365-day period that includes the payment date. In other cases, the dividend withholding tax rate is capped at 15%. The withholding tax rate on both interest and royalties is limited to 5%.
The agreement will enter into force after the exchange of instruments of ratification. Once effective, its provisions will apply in Hong Kong from 1 April of the year following entry into force and in Norway from 1 January of the year following entry into force.
Earlier, the Hong Kong government announced on 13 June 2025 that Hong Kong and Norway have reaffirmed their commitment to expediting the signing of an income tax treaty.
