The France-Norway tax treaty, article by article

The tax treaty between France and Norway was signed in Paris on December 19, 1980. Three amendments modified it in 1984, 1995, and 1999, and the official online text incorporates them. It addresses income and wealth. The administrative list does not mention any inheritance tax treaty with Norway, and Norway is not included in the list of treaties modified by the multilateral tax treaty (MLT). This page presents the articles we were able to read.

A 1980 text, three amendments, no CML

The text. Entering into force on September 10, 1981, it was supplemented by a protocol and an additional protocol. On the French side, it concerns income tax, corporation tax and the "wealth tax", a term added by the 1984 amendment.

The amendments. Signed in Oslo, they date from November 14, 1984 (effective October 1, 1985), April 7, 1995 (September 1, 1996), and September 16, 1999 (December 1, 2002). The current wording of Article 10 § 2 on dividends is derived from the 1995 version.

No CML. The table in the list of amended conventions (BOI-ANNX-000511, version of April 29, 2026) does not include a line for Norway.

Maximum deductions and key rules

To separate a resident of France and Norway

Article 4 defines a resident as a person liable to tax in the State by reason of their domicile, residence, place of management, or a similar criterion. For an individual resident in both States, paragraph 2 considers, in order, their permanent home (then their center of vital interests), habitual residence, nationality, and finally, the agreement of the authorities. A company is considered to be the location of its effective management.

Dividends: four levels depending on direction and ownership

This convention distinguishes the direction of payment: the rates are not the same depending on whether the dividend leaves France or Norway.

General case. Withholding tax "may not exceed 15 percent of the gross amount of dividends" (Article 10 § 2 a).

From Norway to France. If the beneficial owner is a French company that directly or indirectly holds at least 10 % of the capital of the Norwegian company, the Norwegian tax may not exceed 5 % of the gross amount (§ 2 b) i). If this French company directly holds at least 25 % of the capital, the dividends are taxable only in France (§ 2 b) ii).

From France to Norway. If the beneficial owner is a Norwegian company which directly or indirectly holds at least 10 % of the capital of the French company, the dividends are taxable only in Norway (§ 2 c).

The clauses of Article 10 concerning tax credits and French withholding tax are not detailed here.

Salaries: 183 days in the fiscal year

Wages are taxable in the state of residence, unless the employment is performed in the other state. Article 15, paragraph 2, sets out three conditions for this exception: a stay not exceeding 183 days in total "during the relevant tax year," remuneration paid by an employer "resident in the same state as the recipient," and an expense not borne by a permanent establishment or fixed base. The period is the tax year, not a rolling twelve-month period.

Capital gains: the protocol's nationality rule

Gains from immovable property are taxable in the State where the property is situated (Article 13, paragraph 1); those from the property of a permanent establishment or fixed base are taxable in the State where it is situated (paragraph 2). Other gains "are taxable only in the State of which the transferor is a resident" (paragraph 4).

The protocol makes an exception to this rule for substantial shareholdings. Gains on securities of a company resident in one State, realized by a natural person resident in the other State, are taxable in the State of the company if the transferor, alone or with associated or related persons, holds at least 25% of the profits, "has the nationality of the first State without having the nationality of the other State", and has been a resident of the first State at some time in the five preceding years.

Interest, royalties, pensions

Interest and royalties are taxable only in the State of residence of the beneficial owner, without withholding tax. Where a special relationship exists between the payer and the beneficial owner, and the amount paid exceeds what would have been agreed upon by the parties in the absence of such a relationship, the rule applies only to the latter amount (Articles 11 § 5 and 12 § 4). Pensions paid in respect of previous employment are taxable only in the State of residence of the beneficiary, subject to the provisions of paragraph 2 of Article 19 (Article 18 § 1), which are not detailed on this page. Article 18 § 2 deals separately with sums paid under the social security legislation of a State. Its rule is not detailed here.

Other income and wealth

Income not covered elsewhere is taxable only in the State of residence (Article 22). For capital, Article 23 considers the location of real estate, the State of the company for a participation of at least 25% of the profits, and the State of residence for all other assets.

Eliminate double taxation

For a resident of France, the tax credit under Article 24 § 1 is equal to the Norwegian tax, but not exceeding the corresponding French tax, for dividends (Article 10), certain gains (Article 13 § 1 and 3), self-employment, certain salaries, directors' fees, and artists. For other income, it is equal to the corresponding French tax, "provided that the beneficiary is subject to Norwegian tax on that income.".

For a resident of Norway, Article 24 § 2 provides for "a deduction of an amount equal to the income tax paid in France", within the limit of the corresponding Norwegian tax.

Inheritance: no agreement in the list

Norway's entry in the administrative list of April 29, 2026, only mentions income and wealth taxes, without any provisions regarding inheritance or gift taxes. The text I read also limits its scope to these two taxes. This page provides no further information. For other countries, see the list of inheritance treaties.

Mutual agreement procedure

The case must be submitted to the competent authority within three years of the first notification (Article 26).

What this page does not cover

Tax credits and withholding tax, real estate-heavy companies, professors and researchers, cross-border workers, the exchange of information, and the application to the IFI (French wealth tax) are not detailed. They can be found in the consolidated text.

Norwegian dividend of €200,000: numerical example (fictitious profile)

Situation. A fictitious Norwegian company pays out the equivalent of €200,000 in dividends. Three beneficiaries, all residents of France, receive them separately under three scenarios: a French company that directly holds 30 % of the capital, a French company that holds 12 %, and a natural person.

Issue. Everyone wants to know the Norwegian tax ceiling stipulated in Article 10 § 2.

Strategy. They apply the rule of their situation: taxation in France only for 25 % of direct ownership, 5 % for 10 % of ownership, 15 % in the general case.

Result. For the company with 30 shares (%): €0 withholding tax, as the dividend is only taxable in France. For the company with 12 shares (%): 5 shares (%) of €200,000, i.e., a maximum of €10,000. For the individual: 15 shares (%) of €200,000, i.e., a maximum of €30,000. The difference between the individual and the company with 12 shares (%) is €20,000. These amounts are ceilings, not the tax due. The profiles and amounts are fictitious.

What changes depending on your situation

• Your residence as defined in Article 4 and your nationality.
• The direction of the dividend: from Norway to France, or vice versa.
• The percentage of capital held, directly or indirectly.
• The number of days spent in each state during the fiscal year.
• Your share of a company's profits and your years of residence for a transfer of securities.

No result is guaranteed in advance.