The financial services industry supports the underlying principles in the international process to implement new and stricter banking regulation. The new requirements significantly affect Norwegian banks’ operations and their competitive position.

The changes are so extensive that they will have a profound impact on how the financial institutions will have to organise important parts of their operations. In addition, they will increase costs, both because the regulations in themselves entail higher costs and because compliance with the regulations is complicated and requires extensive resources.

In the period ahead, established financial services will be challenged by new companies with new business models. The EU’s revised Payment Services Directive, PSD2, opens up for giving technology companies and other players that do not offer bank accounts themselves, direct access to banks’ payment infrastructure and the opportunity to aggregate account information and debit accounts on behalf of customers. This liberalisation will pave the way for a strong increase in the number of new service providers in several areas, which will intensify competition in the market, while giving consumers greater freedom of choice.

The financial services industry is subject to strict regulatory control and a number of requirements. The growth in financial service production outside the established financial services industry raises complex questions related to everything from deposit guarantees, measures against money laundering and the financing of terrorism, equity capital requirements to ensure financial stability and privacy protection requirements. These are important tasks in society which the financial services industry is loyally complying with, and which will become even more critical when completely new players enter the scene. It is important that the authorities facilitate competition based on fair regulatory parameters in the best interest of the customers. The promotion of competition on equal terms is positive, but must not be at the expense of consumer protection and confidence in financial services and their infrastructure.

New capital and liquidity requirements

The EU capital requirements regulations, called the CRR/CRD IV regulations, entered into force on 1 January 2014. CRR is the regulation, while CRD IV is the directive. The regulations are based on the Basel Committee’s recommendations from December 2010 on capital and liquidity standards, Basel III. The CRR/CRD IV regulations include requirements for own funds, long-term funding and liquidity reserves. The regulations apply to all banks and investment firms within the EEA and will be implemented gradually up to 2019.

Pillar 1

The capital adequacy requirements for banks consist of two pillars. Pillar 1 encompasses minimum requirements and buffer requirements determined by the political authorities. As of 1 July 2016, the total common equity Tier 1 capital requirement was 13.5 per cent for the three banks which the Norwegian authorities have defined as domestic systemically important, O-SIIs (DNB, Nordea Bank Norge and Kommunalbanken), and 11.5 per cent for other banks. This includes a counter-cyclical buffer of 1.5 per cent. The prevailing counter-cyclical capital buffer requirement will increase by 0.5 percentage points, to 2.0 per cent, as of 31 December 2017.

Basel 1 floor

Just like the EU, the Norwegian authorities have chosen to retain the so-called Basel I floor as a security mechanism to ensure that the banks’ capital level does not become too low. In the CRR/CRD IV regulations, the Ministry of Finance has specified that the Basel I floor in Norway is a floor for calculating risk-weighted assets. In the EU regulation, however, the Basel I floor is unambiguously defined as a minimum level of own funds, which is also reflected in the European Commission’s common reporting standard for banks in the EU/EEA. This supervisory practice implies that Norwegian banks appear more weakly capitalised than if the EU’s version of the Basel I floor definition had been used.

Non-risk based capital requirement, leverage ratio

As a supplement to the risk-weighted capital requirements and as a measure to counter adjustments and gaps in the regulations, a non-risk based capital requirement, leverage ratio, will also be introduced. The Basel Committee has recommended and the European Commission has proposed a leverage ratio requirement of minimum 3 per cent as from 2018.

In Norway, the Ministry of Finance has set the minimum leverage ratio requirement at 3 per cent as of 30 June 2017. All Norwegian banks must have a buffer on top of the minimum requirement of minimum 2 per cent. Systemically important banks must have an additional buffer of minimum 1 per cent. As a systemically important bank in Norway, the total requirement for DNB will thus be 6 per cent. At year-end 2016, DNB had a leverage ratio of 7.3 per cent, well above the upcoming requirement.

Pillar 2

The Pillar 2 requirement comes in addition to the other requirements and is intended to reflect institution-specific capital requirements relating to risks which are not covered, or are only partly covered, by Pillar 1. This requirement may vary between banks, depending on the risk factors of the individual bank.
The Pillar 2 requirement for DNB is set at 1.5 per cent common equity Tier 1 capital. New rules for the calculation of the counter-cyclical capital buffer entered into force as of 1 October 2016. For DNB, this means that the counter-cyclical buffer requirement will be the weighted average of the buffer rates for the countries where the bank has credit exposures. At year-end 2016, the common equity Tier 1 capital requirement was 14.7 per cent under Pillar 1 and 2.

There is a need to have a margin over the total common equity Tier 1 capital requirement to take into account expected fluctuations in exchange rates and market prices. In the opinion of Finanstilsynet (the Financial Supervisory Authority of Norway), DNB should have a margin of approximately 1 percentage point, which means that the Group needed to have a common equity Tier 1 capital ratio of approximately 15.7 per cent at year-end 2016. The reason why Finanstilsynet has set this margin is that DNB must be able to retain normal lending growth during a downturn while the capitalisation of the Group must help ensure access to the capital markets even under difficult market conditions. The DNB Group’s common equity Tier 1 capital ratio was 16.0 per cent as at 31 December 2016.

Common equity Tier 1 capital requirement for DNB (incl. management buffer)

Failure to comply with the total common equity Tier 1 capital requirement of 14.7 per cent will not automatically result in restrictions on the allocation of the bank’s profits, including payments of dividends, variable remuneration and interest on additional Tier 1 capital. However, the bank is expected to explain the reason for the situation in writing and to present an action plan to increase capital adequacy or reduce the risk level. This is in line with regulations in other countries. Any decision by Finanstilsynet to introduce restrictions will be based on the different priorities of equity and additional Tier 1 capital when covering losses, which means that restrictions on variable remuneration and dividend payments will be introduced before interest payments on additional Tier 1 capital are reduced.

The Ministry of Finance has approved a regulatory change that clarifies the regulations on the consolidation of capital requirements for banks and insurance companies which entered into force on 31 January 2016. This has implications for how IRB banks that have ownership interests in insurance companies (an IRB bank uses internal models to calculate and report credit risk) should calculate the Basel I floor that is unique to Norway. The regulatory change came into effect on 1 January 2017 and reduces the DNB Group’s common equity Tier 1 capital ratio by approximately 20 basis points.

The Basel Committee has proposed revisions of several parts of the Basel III standards for capital adequacy calculations, aiming, among others, to facilitate comparability of banks’ reported capital adequacy figures and capital requirements. Changes in the standardised approach and the IRB approach have been proposed, along with the introduction of a new capital floor for IRB banks. Revisions of the standards may influence future capital adequacy regulations in the EU and Norway.


The EU capital requirements regulations include stipulations on two quantitative liquidity requirements, the Liquidity Coverage Ratio, LCR, and the Net Stable Funding Ratio, NSFR.

The LCR requires that banks hold sufficient eligible liquid assets to cover, as a minimum, total net payments over a 30-day period under stressed conditions. Net payments thus reflect a possible loss of deposits from customers, public entities and central banks. This requirement was introduced in the EU on 1 October 2015, with a gradual increase to full effect as of 1 January 2018.

In Norway, the LCR will be introduced ahead of the EU schedule. The O-SIIs were required to meet the 100 per cent LCR requirement as early as from 31 December 2015. For other banks, the requirement will be phased in by 70 per cent as of 31 December 2015, 80 per cent as of 31 December 2016 and 100 per cent as of 31 December 2017.

The NSFR requires banks to have an amount of stable funding which, as a minimum, corresponds to the so-called “required amount of stable funding”. Banks are thus required to use stable funding to finance their assets, such as loans and securities. Stable funding is defined as deposits and funding with residual maturities of minimum 12 months or longer. There are weighting rules for both assets and deposits which reflect the items’ liquidity characteristics.

According to the Basel Committee’s proposal, the NSFR requirement must be met by 1 January 2018. On 23 November 2016, the European Commission submitted a proposal for a minimum requirement of 100 per cent. The banks will be given a period of two years to meet the requirement after the regulation enters into force. In Norway, Finanstilsynet has given its recommendation to the Ministry of Finance, stating that the NSFR should be introduced as a minimum requirement for the O-SIIs and other enterprises with total assets in excess of NOK 20 billion as soon as a final decision on the NSFR has been reached in the EU. Until the NSFR has been introduced in Norway, Finanstilsynet will continue to use liquidity indicator 1 when monitoring the bank’s long-term funding. Liquidity indicator 1 resembles the NSFR.


The financial crisis demonstrated the need for better solutions for the winding-up and restructuring of banks. On 1 January 2015, the EU introduced extensive regulations in this field, the Bank Recovery and Resolution Directive, BRRD.

The purpose of the directive is to establish a crisis management system which ensures financial stability by giving banks and the authorities the tools required to prevent and handle crises at an early stage. The crisis management system shall ensure that large banks can be wound up or refinanced without threatening financial stability while deposits and public funds are protected.

Resolution fund and deposit guarantee fund

Under the BRRD, each country will establish a national resolution fund to be used to be used by the resolution authorities as a crisis management tool. In accordance with the revised Deposit Guarantee Directive, each country must also have a deposit guarantee fund. Norway has one of the best capitalised deposit guarantee funds in Europe with total capital that is well above the combined EU requirements to the deposit guarantee fund and the resolution fund of 1.8 per cent of guaranteed deposits in 2024.

The Norwegian deposit guarantee scheme currently covers NOK 2 million. In consequence of the revised Deposit Guarantee Directive, Norway will have to lower its guarantee to EUR 100 000. There is a transitional period up until year-end 2018 for countries with a higher guaranteed coverage level.


A key element in the BRRD is that any losses in connection with the liquidation or recapitalisation of a bank shall be borne by the bank’s investors and not by the taxpayers. Thus, the directive opens up for so-called “bail-in” of banks’ liabilities, which means that unsecured creditors may experience, as part of a crisis solution, that their debt is written down and/or converted into equity. The bail-in rules became effective in the EU as of 1 January 2016. The purpose is to ensure the continued operation of the most important bank functions. In such a situation, investors cannot demand that a bank be wound up in accordance with general liquidation rules, and thus lose leverage with the authorities in cases where the continued operation of a bank is considered to be important to financial stability and the economy.

According to the BRRD, bail-in should be the final alternative, and such measures should not be initiated until the bank is close to insolvency. An underlying principle is that investors, as a minimum, should receive the same financial return as if the bank had been liquidated according to normal insolvency proceedings. Deposits covered by the deposit guarantee will normally be protected from losses.

All banks in the EU must have a minimum level of own funds and eligible liabilities (Minimum Requirement for Own Funds and Eligible Liabilities, MREL) that can be written down or converted into equity (bail‐in) when a bank is close to liquidation. The Financial Stability Board, FSB, has previously proposed a similar requirement whereby global systemically important institutions, G-SIIs, must hold minimum levels of capital and other instruments that can absorb losses or be converted to equity. On 26 November 2016, the European Commission proposed that this requirement, known as Total Loss-Absorbing Capacity, TLAC, be integrated in MREL.

Crisis plans

The BRRD sets a number of other requirements to the institutions. Among other things, banks must prepare recovery plans describing how they will strengthen their capital adequacy and improve their liquidity and funding if their position is significantly impaired. The plans must be approved by the national supervisory authorities. The authorities, on the other hand, must prepare resolution plans for the banks. This will be resource-demanding for the finance industry and entail new, extensive processes vis-à-vis the supervisory authorities.

The implementation of the BRRD and the revised Directive on Deposit Guarantee Schemes will require extensive changes in the Norwegian crisis resolution system, including the rules on public administration and the role of the Norwegian Banks’ Guarantee Fund. The Banking Law Commission has considered how the directives should be implemented in Norwegian law. Among other things, it has been proposed that the banks should pay annual levies to both a deposit guarantee fund and a resolution fund. This will have practical consequences for the current fund structure and the obligation to pay levies. In addition, the Banking Law Commission has proposed that the Ministry of Finance should act as the crisis resolution authority in Norway. The Ministry circulated the draft legislation for public consultation in the autumn of 2016. Crisis resolution rules relating to insurance and pensions will be considered in a separate report to be presented during the first half of 2017.


Due to a stipulation in the Norwegian Constitution on limited access to transfer powers to international organisations, it was not possible to incorporate the EU regulations establishing the European supervisory authorities into the EEA agreement until the autumn of 2016.

The EFTA Surveillance Authority, ESA, has been granted competence by Norway, Liechtenstein and Iceland. to make legally binding decisions addressed to national supervisory authorities and individual institutions in the respective countries. Decisions will be based on drafts prepared by the relevant EU supervisory authority. ESA and the national supervisory authorities in the three EEA/EFTA states shall participate, without voting rights, in the EU’s three European supervisory authorities, EBA, ESMA and EIOPA. Also, the EU supervisory authorities shall participate, without voting rights, in ESA’s work in this field. The same applies to preparatory bodies. The EU supervisory authorities will be granted competence to issue recommendations, that is non-binding decisions, vis-à-vis EEA/EFTA national authorities and enterprises.

The Norwegian government is working to incorporate the remaining several hundred legislative acts on financial services that have been accumulated in the EEA Joint Committee into the EEA agreement and Norwegian legislation. Important legislative acts include the capital adequacy requirements for banks (CRR/CRD IV), the crisis management regulations for banks (BRRD), the revised Directive on Deposit Guarantee Schemes (DGS) and the capital adequacy regulations for insurance companies (Omnibus II).

Debt register and marketing of consumer loans


Credit cards and consumer loans are an integral part of financial institutions’ total product offering. However, these products can also present challenges if individuals incur higher levels of debt than they can manage. Thus, it is important that consumers receive good and correct information about the products and what the consequences will be if they fail to repay their debts in a timely manner.

The Norwegian government wishes to set up a register to prevent individuals from assuming greater personal debt and credit obligations than they are able to afford and has therefore circulated for public comment draft legislation on the registration of individuals’ debt. All institutions granting unsecured consumer credit, such as consumer loans and credit cards, shall have a duty to report such debt to a privately run debt register. The government plans to present draft legislation on the debt register for consideration by the Parliament (Stortinget) in the spring of 2017, and aims to have the register in place in the autumn of 2017.

The plan is that the register should be run by private players by establishing one or more debt register companies approved by the public authorities. Financial institutions will be able to obtain information from the register in connection with credit applications, which will provide a better basis for credit assessments and thus contribute to reducing payment problems among private individuals.


Among other things, the Norwegian Consumer Council has proposed to introduce a ban on the direct marketing of credit cards and unsecured credit to consumers in the form of addressed marketing, telemarketing, door-to-door selling and selling stands. Nor should the marketing emphasise how quickly you can get answers to a credit application or how easily accessible money is. Furthermore, the Consumer Council wants a ban on discounts and bonuses linked to this type of credit agreement and a ban on competitions that encourage taking up credit. The government is considering whether any of the proposals should be followed up in the form of regulations.

New home mortgage lending regulation

The Ministry of Finance has adopted a new home mortgage regulation effective as of 1 January 2017 as a measure against the strong growth in housing prices and household debt, especially in Oslo. The regulation requires that mortgage customers provide a down payment of 15 per cent. Customers who want to buy a second residential property in the municipality of Oslo must provide a 40 per cent down payment.

As previously applied, borrowers must be able to withstand an interest rate increase of 5 percentage points, and this requirement is supplemented by a new provision on the customer’s loan-to-income ratio. Loans are not to be granted if the customer’s total debt exceeds five times gross annual income. Interest-only loans (including home equity credit lines) must not exceed 60 per cent of the property’s assessed value.

Financial institutions may grant loans that do not meet one or more of the criteria in the regulation for up to 10 per cent of the value of total approved loans, but only 8 per cent in the municipality of Oslo. It has been important for the financial services industry to keep this flexibility to be able to grant loans to customers who do not meet all the requirements.

The regulation will remain in effect until 30 June 2018.

The EU’s revised payment services directive, PSD2

PSD2 will enter into force in the EU on 13 January 2018 and will be introduced in Norway through the EEA agreement. The directive will have a profound impact on the regulatory framework for the payment services market.

The directive regulates payments in general, including online payments, and goes a long way in defining new rules of the game for payment service providers. Among other things, banks have to give third party providers direct access to customers’ account balances and transaction history, and the opportunity to transfer money to and from accounts, subject to customer approval. Such third party providers may be other banks, players in the retail industry, pure payment service providers, large digital companies or fintech companies that do not offer accounts themselves. Banks cannot charge a higher price than the ordinary price charged to the end customer.

Allowing third parties to access account information and initiate payments is more common in other countries than in Norway, such as in Sweden, the United Kingdom, China and the US. Based on experience from these markets, there is reason to believe that many consumers will want to take such services into use once they are regulated and made generally available throughout the European Economic Area.

The directive also introduces strict security rules for the authentication of such access as well as enhanced consumer rights and protection against fraud. The European Banking Authority (EBA) will prepare guidelines on security measures when customers initiate payments through third party providers. The final wording of these guidelines could greatly affect public confidence in the payment services and the security of the funds in customer accounts.

PSD2 could pose a threat to traditional banks as the banks’ value chain and customer base will be opened up to new players. However, the changes also give banks the opportunity to develop new products, services and business models. Technology is changing the industry fast, and customers’ expectations are changing even faster.

Finanstilsynet has been given the mandate to look into how PSD2 should be implemented in Norwegian law. A proposal will probably be circulated for public comment in mid-2017.

Regulatory framework for life insurance companies

The regulatory framework for Norwegian life insurance companies has been subject to significant changes over the past few years. On 1 January 2016, new solvency regulations for insurance companies called Solvency II were implemented. In addition, the regulations for occupational pensions and disability pensions have been adapted to the changes made to the Norwegian National Insurance Scheme. The pace of change is expected to slow in the period ahead.

In consequence of the regulatory framework and customer preferences, guaranteed return products are being converted to products where customers can choose between different investment profiles. This is especially evident in the occupational pension market in the private sector, where the majority of large companies have terminated their defined-benefit pension schemes in whole or in part. The transition to products with investment choice means that employees are given greater responsibility for their own pension and must choose the risk level of their actively managed pension funds. In addition, a number of employees have occupational pension schemes that provide a low retirement pension. For this reason, coupled with reduced payments from the National Insurance Scheme, there is an increased need for individual pension savings. The individualisation of occupational pensions requires that products are simple and easy to understand. Over the last few years, pensions have been on the agenda in wage negotiations, and the parties in the labour market, represented by the individual associations in the Norwegian Confederation of Trade Unions and NHO, the Confederation of Norwegian Enterprise, have asked the authorities to issue a report on new product solutions for occupational pensions, referred to as an “Own Pension Account”, as well as the possibilities of having individual pension savings with higher levels of tax relief.

The authorities’ report on an Own Pension Account and private pension savings was handed over to the parties in the labour market in December 2016.


A large majority of employees in the private sector have defined-contribution occupational pension schemes. The product in itself is transparent. However, it gets more complicated as employees receive a pension capital certificate every time they change jobs and must keep track of and take responsibility for these certificates themselves. Accumulating all pension entitlements in one account which follows employees throughout their entire professional career, has been a topic in the Norwegian pension debate for many years. In the autumn of 2016, the authorities described such a product, where the goal is to contribute to:

  • better overview of and information about own accumulated pension entitlements
  • greater freedom of choice and the opportunity to influence the accumulation of pension entitlements
  • more streamlined pension fund management to ensure that pension funds generate the highest possible pension

The Own Pension Account can be realised in many ways. The most logical solution seems to be that companies pay contributions to the life insurance companies in the usual manner, while employees are free to choose the pension provider managing their funds. In addition to funds from the active contribution scheme, each employee’s pension account may also include pension capital certificates issued by former employers and any private pension savings. Such a solution may contribute to a simple and effective pension system. The introduction of an Own Pension Account requires the support of the parties in the labour market. Thus far, support for this solution has not been clarified.


For many employees, the total pension entitlements earned through occupational pension schemes and the National Insurance Scheme provide a retirement pension which is insufficient. Thus, there is a greater need for private pension savings. Over the past few years, the level of private savings through insurance-based schemes has been low. This is because the tax advantages on pension schemes have not been good enough, both due to low tax relief limits and as the income tax rate on pension payments is higher than the tax relief on pension contributions. The authorities’ report on Own Pension Account and private pension savings includes several proposals regarding how the use of tax incentives can stimulate savings. Tax deductions can be linked to employers’ unutilised tax deduction entitlement for occupational pensions. Alternatively, limits can be set independent of employees’ occupational pension schemes. New rules for private pension savings that qualify for tax relief can, in principle, be introduced independent of the Own Pension Account and take effect as from 2018 at the earliest.

Important IFRS amendments

A number of new International Financial Reporting Standards, IFRSs, have been proposed over the past few years. Some of the standards, of which the most important for the banking industry is IFRS 9 Financial Instruments, have already been approved by the standard-setting body, the International Accounting Standards Board, IASB. See description in note 1 Accounting principles to the annual accounts, Approved standards and interpretations that have not entered into force. The amendments will become effective for Norwegian listed companies, including companies issuing listed bonds, after being endorsed by the European Commission and the Norwegian authorities.

Future amendments to IFRS which could be expected to have the most pronounced impact for DNB are new accounting requirements for insurance contracts.


New accounting requirements for insurance contracts have been under review for several years. In 2013, the IASB published an exposure draft on the accounting treatment of insurance contracts. The standard was previously called IFRS 4 Phase II and has been renamed IFRS 17 Insurance Contracts. The exposure draft and comment letters have since been subject to review and discussion in the IASB, and a number of issues relating to the accounting requirements for insurance contracts are still under review.

The exposure draft proposes that insurance liabilities be measured at the present value of the cash flows arising from the insurance contracts, including a risk margin and a service margin. The effects of changes in estimated cash flows and the discount rate, respectively, shall be recognised in profit or loss or in other comprehensive income according to special rules. The proposal is expected to result in greater complexity in preparing and presenting the financial statements. Under the current standard, liabilities are measured according to requirements which are further defined in the Act on Insurance Activity, and changes in insurance liabilities are recognised in profit or loss.

The final requirements are expected to be published in the first half of 2017, and it has been proposed that the new standard should enter into force as of 1 January 2021. Special transitional rules for insurance companies relating to IFRS 9 have been prepared, since IFRS 17 will become effective after the introduction of IFRS 9.

Taxes and fees for the financial services industry


BEPS (Base Erosion and Profit Shifting) is a political project initiated by the OCED to gain better insight into the global structures of multinational enterprises and ensure that tax is paid where income is generated. Recommended measures for implementation in national legislation, tax treaties and OECD guidelines, particularly with respect to transfer pricing, were presented on 5 October 2015.

The recommended measures are under implementation in national legislation in several countries where DNB has operations. In Norway, some measures have already been initiated, and other measures are expected to be implemented in the period ahead. A multilateral treaty, presented on 24 November 2016, has been negotiated to enable amendments to bilateral tax treaties. The BEPS project will thus result in extensive changes in international taxation. DNB will have to relate to a number of the changes as and when they are introduced. Moreover, BEPS will entail more extensive documentation requirements and stricter supervisory control, partly due to the requirement for country-by-country reporting. The extensive changes in both national legislation and tax treaties will increase the risk of double taxation.


With effect from 2017, the corporate tax rate has been reduced to 24 per cent. After a tax compromise was reached by the Norwegian parliament (Stortinget), the tax rate on ordinary income will be reduced to 23 per cent by 2018. With respect to companies that are liable to financial activities tax, the current tax rate for 2016 of 25 per cent will be retained, cf. the paragraph on financial activities tax below.


Financial services are exempt from value added tax. The Norwegian government is now following up the Scheel Committee’s recommendation to introduce a financial activities tax, partly to compensate for the fact that such services are exempt from VAT. The Ministry of Finance states that, ideally, the financial activities tax should be designed to have all of the neutrality qualities of VAT, but that it has not been possible to introduce such a tax from 2017. Consequently, a simpler form of financial activities tax in the form of two elements has been introduced:

  • an additional tax of 5 per cent on the payroll of companies in the financial services industry. For DNB, this tax is estimated at approximately NOK 400 million before tax each year
  • a continuation of the 25 per cent tax rate, while the tax rate for companies that are not liable to financial activities tax will be reduced to 24 per cent

Financial activities tax will be determined on the basis of the company’s total payroll liable to employer’s national insurance contributions. The tax base for the financial activities tax is thus the same as for the calculation of employer’s national insurance contributions. Financial activities tax on salaries will be tax deductible just like other wage costs. The 25 per cent tax rate will apply to all companies covered by the extra payroll tax. The financial activities tax will be levied on all companies with employees in the finance and insurance sectors.

However, no financial activities tax will be levied on

  • companies with less than 30 per cent financial activity
  • companies with more than 70 per cent financial activity subject to VAT

Denmark has long had a financial activities tax (“payroll tax”).


The government has announced that it will review a proposal to introduce withholding tax on cross-border interest payments and that it aims to submit a consultation paper in 2017. Withholding tax on cross-border interest payments will be a Norwegian tax on international creditors.