United Kingdom

Tax treatment of dividend shares

Norway Royal Salmon (NRS/ the Company) has registered that the distributed "Share Exercise 2015 form (Aksjeoppgave)" from the Norwegian Tax Authorities, related to the tax liability for the portion of the dividend paid in 2015 as dividend shares, does not treat the taxation of dividend shares in accordance with how NRS have perceived the tax regulations. NRS's assessment is that the portion of the dividend received as dividend shares is not taxable dividend, while the part of the dividend that is paid as cash is taxable dividend.

Below are excerpts of the stock exchange report for notice to Annual General Meeting in 2015, where NRS’s assessment of the tax rules is described:

The Company generally does not seek to determine, nor comment on, the tax position of its individual shareholders. However, note that the Company will take the position that the distribution of shares does not constitute a distribution of dividends for Norwegian tax law purposes. Accordingly, the Company will not withhold any withholding tax for its no-Norwegian shareholders. Norwegian shareholders’ cost price for the shares being distributed is assumed to be zero.