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Germany - Norway Tax Treaty (as amended by 2013 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Entry into Force

(1) This Convention shall be ratified and the instruments of ratification shall be exchanged at Bonn as soon as possible.

(2) The Convention shall enter into force upon the exchange of instruments of ratification and its provisions shall have effect:

  • (a) In respect of taxes withheld at the source for amounts paid or credited on or after 1 January 1991;
  • (b) In respect of taxes on income and capital for the calendar year 1991 (or the fiscal year ending in that year) and subsequent years.

(3) Notwithstanding the foregoing provisions of this Article, the tax charged pursuant to Article 10, paragraph (4)(a), on dividends (within the meaning of paragraph (6) of that Article) distributed before 1 January 1992 may exceed 5 per cent of the gross amount of the dividends but shall not exceed 10 per cent thereof.

(4) Upon the entry into force of this Convention, the Agreement between the Kingdom of Norway and the Federal Republic of Germany for the avoidance of double taxation and concerning reciprocal administrative and legal assistance with respect to taxes on income and capital and to the business tax, signed at Oslo, on 18 November 1958,1 shall cease to have effect and shall not thenceforth apply to the taxes to which, in accordance with the provisions of paragraphs (2) and 3, this Convention applies.