Statutory rate without a valid treaty claim: 30%.
Rates on investment and other income
Treaty in effect generally from Jan. 1, 1971. Protocols in effect from: Jan. 1, 1982. IRS country code NO.
| Income | 1042-S code | Treaty rate | Article |
|---|---|---|---|
| Interest paid by U.S. obligors, general | 01 | 0% (exempt)s | 9 / PV |
| Dividends paid by U.S. corporations, general | 06 | 15% | 8(2) / PIV(1) |
| Dividends qualifying for the direct dividend rate | 07 | 15% | 8(2) / PIV(1) |
| Royalties: industrial, commercial or scientific equipment | 10 | n/au | 10(1) |
| Royalties: know-how and other industrial royalties | 10 | 0% (exempt) | 10(1) |
| Royalties: patents | 10 | 0% (exempt) | 10(1) |
| Royalties: motion picture and television copyrights | 11 | n/au | 10(1) |
| Royalties: copyrights (including software, unless the treaty says otherwise) | 12 | 0% (exempt) | 10(1) |
| Pensions and annuities | 15 | 0% (exempt)f | 18(1) |
| U.S. Social Security benefits (applies to 85% of the payment) | 15 | 30% | 19 / PVIII |
"n/a" means the payment type is not covered by the royalty article: equipment leasing is business profits (no withholding without a permanent establishment) or other income. Superscript letters are the IRS's own conditions, listed at the end of this page.
Pay for personal services performed in the United States
Each row is an exemption the treaty gives, with the limits the IRS lists. All conditions in a row must be met; if any is not, the pay is withheld on at 30% (contractors) or under the wage rules (employees). Services performed entirely outside the United States are foreign-source and need no treaty claim.
| Code | Purpose | Maximum presence in U.S. | Required employer or payer | Maximum amount | Article |
|---|---|---|---|---|---|
| 16 | Scholarship or fellowship grant515 | 5 years | Any U.S. or foreign resident | No limit | 16(1) |
| 17 | Independent personal services7 | 182 days | Any contractor | No limit | 13 |
| 42 | Public entertainment28 | 90 days | Any contractor | $10,000 p.a. | 13 |
| 18 | Dependent personal services17185659 | 182 days | Norwegian resident | No limit | 14 |
| 19 | Teaching4 | 2 years | U.S. educational institution | No limit | 15 |
| 20 | Remittances or allowances | 5 years | Any foreign resident | No limit | 16(1) |
| 20 | Compensation during training | 5 years | U.S. or any foreign resident | $2,000 p.a. | 16(1) |
| 20 | Compensation while gaining experience2 | 12 consec. mo | Norwegian resident | $5,000 | 16(2) |
| 20 | Compensation under U.S. Government program | 1 year | U.S. Government or its contractor | $10,000 | 16(3) |
How the payee claims these rates
- Individuals claim a reduced rate on interest, dividends, royalties or pensions in Part II of Form W-8BEN: treaty country, article, rate and any conditions. Most claims need a U.S. TIN or a foreign TIN on the form.
- Entities claim in Part III of Form W-8BEN-E, which also asks which limitation-on-benefits test the entity meets (the Norway treaty's LOB provision is Article 20).
- Pay for services performed in the United States by an individual is exempted on Form 8233, not the W-8BEN, one form per tax year and per payer.
- The payer reports the payment on Form 1042-S with the income code shown above and chapter 3 exemption code 04 (exempt or reduced withholding under a tax treaty). From 2026 an exemption code is required whenever less than 30% is withheld.
The rate in a table is the most the United States may withhold under the treaty, not an entitlement. The payee has to be a resident of Norway under the treaty, the beneficial owner of the income, and (for entities) meet the limitation-on-benefits article, and the payer has to hold a valid certificate before the payment. The IRS tables are a summary: check the article itself when the amount is material.
Questions payers ask
What is the U.S. withholding rate on dividends paid to a resident of Norway?
15% on dividends generally and 15% on dividends qualifying for the direct dividend rate, under Article 8(2) / PIV(1), if the shareholder documents the claim on a W-8BEN or W-8BEN-E. Without a valid claim the rate is 30%.
What is the U.S. withholding rate on royalties paid to a resident of Norway?
0% on copyright and software royalties (income code 12), 0% on patent royalties and not covered by the royalty article on film and television royalties, under Article 10(1).
What is the U.S. withholding rate on interest paid to a resident of Norway?
0% under Article 9 / PV, before considering the Code's own exemptions for portfolio interest and bank deposit interest.
Is a contractor from Norway working in the United States exempt from U.S. withholding?
Under Article 13, pay for independent personal services is exempt if the contractor is present in the United States for no more than 182 days, subject to the conditions in the article. An individual claims the exemption on Form 8233; without it, withhold 30%.
Do we withhold on a contractor from Norway who works only outside the United States?
No. Pay for services performed entirely outside the United States is foreign-source income: no withholding and no Form 1042-S. Keep the contractor's W-8BEN or W-8BEN-E on file.
The IRS notes behind the figures
Notes to the rates (IRS Table 1)
- f Includes alimony.
- s In Norway, the rate is 0% so long as Norway continues to exempt from tax interest derived within Norway (not attributable to a permanent establishment in Norway) by persons not resident in Norway.
- u If enterprise earns income from leasing of equipment in the conduct of a trade or business, covered by Business Profits article (net tax). If passive income from the leasing of equipment, and not in Royalty article, covered by the Other Income article, if any. In Pakistan payment for TV broadcasting rights are covered by the Royalty article but not rental income from motion picture films.
Notes to the services table (IRS Table 2)
- 2 Applies only if training or experience is received from a person other than alien's employer.
- 4 Does not apply to compensation for research work primarily for private benefit.
- 5 Grant must be from a nonprofit organization. In many cases, the exemption also applies to amounts from either the U.S. or foreign government. For Indonesia and the Netherlands, the exemption also applies if the amount is awarded under a technical assistance program entered into by the United States or the foreign government, or its political subdivisions or local authorities.
- 7 Exemption does not apply to the extent income is attributable to the recipient's fixed U.S. base. For residents of Korea and Norway, the fixed base must be maintained for more than 182 days (for Norway, 30 days in the case of the exploration or exploitation of the seabed and sub-soil and their natural resources); for residents of Morocco, the fixed base must be maintained for more than 89 days.
- 15 Does not apply to payments from the National Institutes of Health under its Visiting Associate Program and Visiting Scientist Program.
- 17 The exemption does not apply if the employee's compensation is borne by a permanent establishment (or in some cases a fixed base) that the employer has in the United States.
- 18 The exemption also applies if the employer is a permanent establishment in the treaty country but is not a resident of the treaty country.
- 28 Exemption does not apply if compensation (or gross income for the Philippines and Romania) exceeds this amount.
- 56 Labor or personal services performed in connection with the exploration or exploitation of the seabed and sub-soil and their natural resources is fully exempt for a period of 60 days in the tax year.
- 59 Income from personal services performed by a resident of one contracting State as an employee aboard ships or aircraft operated by a resident of the other contracting State in international traffic may be taxed by that other contracting State if the employee is a member of the regular compliment of the ship or aircraft.
Transcribed from the IRS Tax Treaty Tables. Treaty texts and technical explanations: United States income tax treaties, A to Z.
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