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Norway; Qatar

21 December 2009

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Treaty between Norway and Qatar – details

Details of the income tax treaty and protocol between Norway and Qatar, signed on 29 June 2009, have become available. The treaty was concluded in the Norwegian, Arabic and English languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention.
The maximum rates of withholding tax are:

-   15% generally on dividends; 5% on dividends if the beneficial owner is a company (other than a partnership) which owns directly at least 10% of the capital of the company distributing the dividends (Art. 10(2));
-   0% on interest (Art. 11(1)); and
-   5% on royalties (Art. 12(2)).

Deviations from the OECD Model include that:

-   the term "permanent establishment" (PE) includes especially sales outlets and a farm or plantation and any other place of exploration and exploitation in addition to extraction of natural sources (Art. 5(2));
-   the term PE also encompasses: (i) a building site, a construction, assembly or installation project or connecting supervisory activities provided that such site, project or activities continue for a period of more than 6 months (Art. 5(3)(a)); (ii) the furnishing of services, including consultancy services, by an enterprise through employees or other personnel engaged by the enterprise for such purpose, provided that such activities for the same or a connected project within a contracting state continue for a period or periods aggregating more than 6 months within any 12-month period (Art. 5(3)(b));
-   an insurance company is, except in the case of reinsurance, deemed to have a PE in the other contracting state, if it collects premiums in the territory of that state or risks arising in that state are insured, by means of a person other than an independent agent (Art. 5(6));
-   the term "royalties" includes films and tapes used for radio or television broadcasting (Art. 12(3));
-   the treaty contains a provision regarding independent personal services based on Art. 14 of the UN Model Convention;
-   pensions and other payments made under the social security legislation of a contracting state are only taxable in the source state (Art. 18(1));
-   the treaty includes a provision regarding offshore activities. Under this provision a person carrying out offshore activities in the other contracting state is deemed to have a PE there if those activities exceed 30 days in the aggregate in any 12-month period, (Art. 21);
-   income derived by a resident of a state from the other contracting state, which is not covered by any other treaty provisions, is taxable in both states (Art. 22(3));
-   the treaty includes a limitation of benefits clause (Art. 23) and
-   the non-taxation of Qatari nationals and other members of the Gulf Cooperation Council (GCC) nations under Qatari tax law will not be regarded as discriminatory (Art. 25(4)).

Both states generally provide for the exemption-with-progression and credit methods to avoid double taxation (Art. 24(a) and (b)).
Neither treaty party can terminate this treaty during a period of 5 years starting from the date of its entry into force (Art. 30(1)).

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