China and Norway’s new income tax treaty entered into force on 16 June 2026, replacing the 1986 agreement and setting withholding tax rates on dividends, interest and royalties.
China’s State Administration of Taxation has announced that the new income tax treaty between China and Norway entered into force on 16 June 2026.
The treaty, signed on 12 May 2023, replaces the tax treaty between the two countries that was concluded in 1986.
The treaty applies to Chinese individual income tax and enterprise income tax, while covering several Norwegian taxes, including the national tax on income, county municipal tax on income and municipal tax on income. It also covers the national tax relating to income from the exploration for and the exploitation of submarine petroleum resources and activities and work relating thereto, including pipeline transport of petroleum produced, as well as the national tax on remuneration to non-resident artists.
Under the treaty, withholding tax on dividends is capped at 5% where the beneficial owner is a company that directly holds at least 25% of the paying company’s capital throughout a 365-day period that includes the date of payment. In other cases, the rate is 10%.
Interest is subject to a 10% withholding tax rate, with an exemption where the interest is beneficially owned by the Government of a Contracting State or paid on loans guaranteed or insured by the Government of a Contracting State. Royalties are subject to a 10% withholding tax rate.
Earlier, the Norwegian parliament (Storting) approved a new income tax treaty with China on 21 April 2026.
