The Norwegian tax authorities have introduced a 3 year statute of limitation on withholding tax reclaims, effective from 1 April, 2004. This means any tax reclaims filed later than 3 years from the payment date will not be honoured, unless an applicable double taxation treaty stipulates otherwise. Reclaims dated 1995 or earlier are already barred from consideration.
“Reclaims dating from 1996 that are submitted to the tax authorities before 1 April 2004 will be taken into consideration under the three year deadline,” says a spokeswoman for DnBNOR in Oslo. “Any received after this date will be considered time-barred. The 3 year deadline also applies to reclaims that have been submitted previously and rejected due to insufficient information or documentation. If a rejected reclaim is older than 3 years, the statute of limitations for re-submitting the application is defined as 6 months from the date of the rejection. Failing this, a reclaim after this period will be considered time barred. Clients with outstanding claims should submit them as soon as possible. In order to avoid delays, clients should pay special attention to the requirements or previous grounds for refusal.”