Norway and Qatar have agreed to amend their tax treaty to align it with OECD BEPS standards, strengthening anti-avoidance rules and information exchange while leaving existing withholding tax rates unchanged.
In an update, Norway’s government clarified that the protocol amending the 2009 income tax treaty between Norway and Qatar entered into force on 4 September 2025. The amendments modernise the treaty in line with OECD BEPS standards and strengthen anti–tax avoidance provisions.
Signed on 4 September 2024, this is the first amendment to the treaty and includes the following changes:
- Updated treaty title and preamble, explicitly referencing the prevention of tax evasion and avoidance and aligning the agreement with OECD anti-BEPS principles.
- Introduction of a principal purpose test (PPT) under the revised “Entitlement to Benefits” article, denying treaty benefits where obtaining them was one of the main purposes of an arrangement unless consistent with the treaty’s objectives.
- Enhanced exchange of information provisions, fully aligned with OECD standards, including access to banking and ownership information and expanded information-sharing rights between the tax authorities.
- Revised offshore activities rules, clarifying the interaction with other treaty provisions.
- Expanded information-sharing permissions, including onward exchange to third states subject to authorisation.
The protocol does not amend the existing withholding tax rates under the treaty. Dividends, interest, and royalties remain subject to the rates set out in the current Norway–Qatar tax treaty.
Earlier, on 13 November 2025, Qatar issued a decree approving the protocol amending its 2009 income tax treaty with Norway.
