Decree No. 12,406/2025 enacted the Treaty to Avoid Double Taxation signed between Brazil and the Kingdom of Norway.
The Brazil-Norway Treaty was drawn up based on the OECD (Organization for Economic Cooperation and Development) model convention, applying to both Income Tax and the Social Contribution on Net Profit on the Brazilian side.
The Treaty establishes limits (10% or 15%, as applicable) for income characterized by dividends, interest and royalties, with specific provision for income from technical services and technical assistance (10%).
There is a specific provision for offshore activities, including exploration of the seabed, subsoil, and natural resources, as well as directly related activities (transportation of supplies and personnel).
The elimination will be through the granting of credit corresponding to the tax actually paid.
It is up to companies operating in such countries to analyze the provisions of the Treaty in order to choose the most appropriate structure from a tax perspective.
