Norway: Tax authority claims that joint Nordic audit focused on securities lending practices reveals avoidance of dividend withholding tax
Several securities lenders have received reassessment notices.
The Norwegian Directorate of Taxes on January 21, 2026, issued a press release announcing that a joint Nordic audit focused on securities lending practices revealed that certain professional financial actors have made deliberate adjustments to avoid dividend withholding tax.
According to the tax authority, both Norwegian and international market participants have exploited tax rules for financial gain, resulting in an estimated NOK 1–2 billion in annual tax losses due to tax-motivated share lending.
KPMG observation
The press release does not mention that securities lending can occur for legitimate reasons unrelated to dividend withholding tax avoidance. KPMG professionals are aware that following the audit, several non-Norwegian lenders of Norwegian securities have received dividend withholding tax reassessment notices that rely on domestic tax provisions, including the general anti-avoidance rule. Taxpayers receiving such reassessment notices need to respond promptly and consider challenging the tax authorities’ position in the notices.
For more information, contact a KPMG tax professional in Norway:
Thor Leegaard | thor.leegaard@kpmg.no
Perry Sebastian Breesth | perry.breesth@kpmg.no