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noralliansen530 bilde fra stein


NorAlliansen er organisasjonen for skandinaver bosatt i utlandet.

NorAlliansen har en rekke områder som organisasjonen vil fokusere på. Blant de sakene som NorAlliansen vil arbeide med fra starten er skatt og skattesaker. Selvsagt vil da ”kildeskatten” være en av sakene her, men vi vil også å få Norge til å respektere inngåtte skatteavtaler.

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Date: 2011-06-09

Helse og Omsorgsdepartementet, Norway

v/ Opheim and Sundrehagen
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Copy to:

The Cyprus Ministry of Finance, Inland Revenue Department

NorAlliansens Chairman of the Board 



The Mayor of Paphos


Dear Sundrehagen and Opheim


Communication with the Authorities about promoting Cyprus as the most attractive Country in EU
and EU-Commission/ESA regarding the present and future Tax Agreements between Norway and Cyprus


First of all we will give you credit for a friendly phone calls last week between the President of NorAlliansen and you regarding the above-mentioned issues. We thank you also for surprising good and swift response on our information about NorAlliansens conference in Cyprus on 14the May 2011 that fully support our plans to promote Cyprus as the most attractive country to visit especially for the elderly and help strings pensioners who will be able tomake significant contributions to reduce a growing problem in Norway Nordic countries, namely the increasing growth in the sector and the countries' welfare budget.

Anita Oppheim understood the message quickly and then gave the phone number of Sundrehagen as the right person to contact.It seemed very professional to be connected to you (Sundrehagen) in seconds, and that you after a few minutes concluded by showing great interest of the message above and finished the conversation by asking for written a written documentation of our ideas.

As previously employed as a telecommunications manager in Hydro Aluminium, I can say that this professional communication can compete with a “world class” private enterprise who have to compete on the top of a global market.The experience that the undersigned met in a large organization such as Health and Care Services is in stark contrast to our extensive communication with other public agencies in Norway and abroad such as the Tax and National Insurance Departments where you have to wait hours to get to talk to a person if you don’t resign and hang up.

As agreed, we hereby forward a report we made after the conference that NorAlliansen recently held here in Cyprus on 14th of May 2011 where we highlighted these major benefits:

- That Norway and the Nordic countries can reduce their welfare budget by adding a better framework for older people go to Cyprus for a shorter or longer period of time for care or reconvalesence.
- That Cyprus can improve the country's economy as more immigrants come here, pay taxes here and use the major part in their pension and pay indirect taxes.
- That Cyprus can improve its finances by attracting more travelers/visitors which pay indirect tax here.
- That the elderly in Norway / Scandinavia experience positive health effects by taking a shorter or longer stay in a country with the best climate in Europe.

As mentioned in our telephone conversation, we focused at the above Conference on the possibilities - on the one hand for Norway /the Nordic countries to reduce their welfare expenditure budgets, and the possibility for Cyprus to increase its tax revenue from a constructive cooperation in this area.

The report from the conference and our follow-up letter to the mayor is published in our website, http://www.Noralliansen.org- (both documents in pdf. format) together
with positive information about Cyprus in general and taxation in particular.


Onthis basis,we want to makespecialnoteof thelastchaptersinourinvitationto the above-mentioned

conferencewherewewritethe followingabout

The Consequences of following this recommendation:

ü The goals according to item 1 will be realized. As mentioned in NorAlliansens letter to The Ministry of Finance and the AKEL dated 2010-05-31 we take it for 2010 granted that a new Tax agreement between Cyprus and Norway must be based on EUs rules. See




The consequences of NOT carrying out this recommendation:

If Norway, a Nordic country, is allowed to proceed with the curtailment of retirement pensions, or, alternatively, an agreement of a new tax treaty with Norway which does not give Cyprus the exclusive right to tax pensions according to the German model, and if the Tax Administration in Norway are not stopped by the EU-ESA, it has the consequence of loss of tax revenue for Cyprus.

We will, in that case,
recommend emigrants to move to a country where the pension is only taxed in the country of residence - and not in Norway. Relevant countries are Spain, Greece, Malta, Italy, France and Portugal, which has introduced 10-year tax exemption for retirees from any country within EU who move to their country. See attachment 1.


We look forward to hearing from you.

Yours Sincerely
for NorAlliansen
- The Northern Alliance Global

The global organization for Scandinavian expatriates


Jakup Skamsar (President)


Attachment 1

Letters and communications with the Cyprus Authorities, politician, EU-Commission, ESA (EFTAs Controll Unit for non EU members) regarding the present and future Tax Agreements between Norway and Cyprus

- 2011-05-05 Invitation to an Conference re How to make Cyprus to the most attractive Country in EU. See:



- 2010-11-27 Letter to ESA (with copy to EU-commission) regarding the Norwegian double taxation and withholding taxin Cyprus. See



- 2010-05-31 Letter to Minister of Finance, Charilaos Stavrakis, 1439 Lefkosia CYPRUSWith the headline:

”Any new Tax agreement between Cyprus and Norway must be based on EU rules”. Copy to Charis Kyriakides, AKEL Paphos, and Spokesman of AKEL, Stavros Evagorou. (*) See:



- 2010-02-10 Letter to the Minister of Finance (with copy to AKEL regarding Norway’s double taxation and

establishment of taxation at source on pensions to Norwegian citizens living in Cyprus. (*) See:



- 2010-01-29 Verbal Note sent by the Cyprus Embassy in Stockholm to the Norwegian Ministry of Foreign Affairs. See:



- 2009-06-06 letter to AKEL, Paphos and copy to the Minister of Finance, Regarding Norway’s establishment of taxation at source on pensions to Norwegian citizens living abroad will make Cyprus less attractive as a country to retire to. See:



Please find also enclosed 2 links regarding:

“Commission opens public consultation on double taxation problems in the EU”

=>   http://ec.europa.eu/taxation_customs/common/consultations/tax/2010_04_doubletax_en.htm

This is, as far as I can see, breakings news for Norwegian expatriates and for Cyprus.    

The Information transmitted is intended to be open for the person or entity to which it is addressed and does NOT contain confidential and/or privileged material.  Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon, this information by persons or entities other than the intended recipient is NOT prohibited.  If you received this in error, please contact the sender and delete the material from any computer.  The information contained in this email is for general guidance on matters of interest only.







Previous letter
The letter below has not been answered.
To ESA/EFTA                                                                             Date 2010-11-22
Re.: Norway’s double taxation and withholding tax on pensions to Norwegian citizens in Cyprus.
On the background of a number of specific cases of double taxation and improper taxation of Norwegian pensioners with small pensions who are resident of Cyprus, we kindly ask you to do your utmost to stop theunlawful pension curtailment.This must happen as soon as possible as we have got many requests for help from pensioners who maintain that this practice is detrimental to their health and standards of living.

1) As a basis for this request, we have assumed the following conditions:
The so-called withholding tax affects in particular people with disability and living on a minimum pension.
The Norwegian Senior organization says:
The withholding tax affects the poorest: See:

Even if your mandate applies to countries inside the EU/EØS area,
we find reason to emphasize that the Norwegian practice has serious consequences both inside and outside the EU.It shows that the Tax Administration’s curtailment of the accrued pension and social security rights is global and violates several unanimous Supreme Court judgments in Norway, the EU's basic rules and prohibits retirees and others to move freely within the EU / EEA, and international conventions and(tax) agreements.

2) When the tax authorities in Norway curtails pensions remitted to retirees who are resident of Cyprus (and other countries), pensioners with small pensions will suffer. This unlawful pension curtailment is mainly due to:
2.1Double taxation (a resident of Cyprus is taxed in Norway in addition to being taxed in Cyprus)
2.2The unfair taxation of pensioners who have so small benefits that they do not pay tax according toCyprus tax legislation which is currently limited to €19,500
2.3 We believe that Norway does not have the authority to impose withholding tax on pensions in Cyprus in accordance with local tax laws and in accordance with the tax treaty with Norway.

The impression we got from NorAlliansens network, is thatthe majority of all overseas pensioners are:
people with incomes so low that they have trouble maintaining reasonable living conditions in high-cost Norway,
3.2) persons who, for health reasons emigrate to warmer climates, or
3.3) immigrants who after retirement moved back to their home country.
This impression is best strengthened by their low pension average.

4) According to the described situation it seems inaccurate to argue that the withholding (source) tax will prevent that the "Norwegian tax bases ... be undermined in an unreasonable manner," as the Ministry of Finance in Norway put it. (Page 36 of consultation paper).The majority of those pensions would not be taxed according to Norwegian tax regulations. On the contrary, these pensioners are likely to save the Norwegian society for significant social costs, not the least because it concerns the elderly, often frail and sick people.
5) The background of the double taxation is that Norway unilaterally insists on taxing any Norwegian expatriate for the year that they move to another country plus the next three years, thereby depriving the resident country for tax revenue up to 4 years after they have become a resident of Cyprus. This practice is a breach of the Tax Treaty between the countries. The Norwegian Authorities has been informed of this illegal practice by our organization to no avail.
6) In this connection it is interesting to note the following section in a speech earlier Attorney Bjørn Haug held in a French pensioner association 13March 2009, and which also has to do with identity wrote:

"The Norwegian authorities have in some cases required documentation that the pensions in question are actually taxed abroad. The practice of the Norwegian authorities is, in my opinion, not according to the law.
At the moment it is accepted that under Norwegian law that the applicable pension should not be taxed in Norway and it is irrelevant whether or how the new country of residence is implementing the taxation. It is, in my opinion, not legal to substitute tax in the new country of residence as a condition for omitting Norwegian taxation, "

We hope that you will look into this matter, and make the proper, formal representations to Norway.

6) Consequences
6.1. The consequences of this practice are very serious for all Norwegian pensioners that now are residents of Cyprus. They will now consider moving to another country which do not accept that the Norwegian tax authorities set aside binding tax treaties. This practice will also have as a consequence that Norwegian retirees will reconsider any planned move to Cyprus.
6.2 Our organization will not be able to recommend Cyprus as a future home for this category of pensioners if you do not help us to put an end to this illegal practice of taxing expatriate Norwegian retirees by the Norwegian Tax Authorities, and request that all Cyprus residents be exempted from tax to Norway.
6.3 We can inform you that the Norwegian Minister of Finance recently told Norwegian media that pensioners in Spain will be taxed there in line with local tax practices, and not be taxed in Norway – avoiding any double taxation.We have reason to believe that the Spanish Authorities, organizations and tax experts has contributed to the fact that resident Norwegian retirees are assured that the local (Spanish) authorities look after their interests after they have made the serious decision to move to another country with a more pleasant climate. A copy of this article can be read at this link both in Norwegian and English language. See:
6.4 The Norwegian leading magazine for personal economy has quoted the Norwegian Minister of Finance saying that “we are now stopping tax refugees” with special reference to Cyprus.It seems that Norway still consider Cyprus as a ‘tax heaven’, not realizing that Cyprus now is bound by EU regulations regarding off-shore companies which are (have been) tax exempt.
6.5. With the above in mind, we kindly ask you to clear up this sorry state of affairs. NorAlliansen
hope that EUs authorities clearly state that any breach of the Tax Treaty will not be accepted, and a continued Norwegian taxation of Norwegian retirees resident in Cyprus will be stopped by ESA which we understand is EFTA’s controlling authority, as well as to the relevant EU authorities. As an associated member of EU, we hope that Norway is bound by EU’s rules and regulations.
NorAlliansen requests a meeting with the EUs authorities regarding this case as soon as possible to prevent Norwegian pensioners to disregard Cyprus as a future country of residence. The meeting can take place either in Cyprus, Brussels or Norway.
We look forward to hearing from you as soon as possible and preferably within three weeks as we plan a press conference in Paphos regarding this case.

We kindly ask you to contribute to a more equitable tax system for foreign residents are pensioners.Norway cannot sustain the law relating to withholding (source) tax as it is currently designed.
The EU country, Germany has a tax model that, according to our sources, mean that taxation in Germany ceases as soon as it is presented with a so-called Tax Resident Certificate which certify that one is taxable in the country of residence according to local tax laws and tax treaty with Norway.

Social Democrats party and the opposition party in Germany have agreed on this model. See:

As critical as the situation is to many retirees - both in and outside the European Economic Area are, we kindly ask you to establish the same tax model for Norwegian pensioners in Cyprus and other countries in Europe that is extremely simple for all – first of all for the retired and older people, but also for the Governmentin Norway and the country of residence.Can the tax model bee more simple than the German? The consequence will be that as soon as Norway gets a Tax Resident Certificate, they have to stop taxation in Norway.

It is crucial that retirees with the smallest pensions are given priority, so that withholding tax will be stopped when it is clear that the taxpayer can claim tax exemption according to the present tax rules in Norway.
NorAlliansen believes that Norway should be stopped in this attempt to undermine the EU's pillar and the prohibition of discrimination and / or implement the tax obstacles so that seniors and others can move freely from one country to another within the EU / EEA.

We assume that the tax authorities in Norway can’t discriminate retirees within and outside the EU without compromising its reputation abroad.

for NorAlliansen

Jakup Skamsar(President)
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