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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.


Taxes Covered

*(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.

*(2) There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property and taxes on capital appreciation.

*(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) In the Federal Republic of Germany:
    • (i) the income tax,
    • (ii) the corporate tax, and
    • (iii) the trade tax,
  • including the fees imposed on them
  • (hereinafter referred to as "German Taxes");
  • (b) In the Kingdom of Norway:
    • (i) the income tax assessed by the State (inntektsskatt til Staten),
    • (ii) the income tax assessed by the government districts (inntektsskatt til fylkeskommunen),
    • (iii) the income tax assessed by the communities (inntektsskatt til kommunen),
    • (iv) the State assessed tax on earnings from the exploration and exploitation of oil reserves found under the sea and therewith associated activities and work including the transport of pumped oil through pipelines (skatt til Staten vedrørende inntekt i forbindelse med undersøkelse etter og utnyttelse av undersjøiske petroleumsforekomster og dertil knyttet virksomhet og arbeid, herunder rørledningstransport av utvunnet petroleum), and
    • (v) the State assessed tax on the compensation of foreign artistes (skatt til Staten på honorar til utenlandske artister)
  • (hereinafter referred to as "Norwegian taxes").

(4) The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes.