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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 and on capital imposed on behalf of each 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 and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are:

  • (a) in Czechoslovakia:
    • (i) the taxes on profits;
    • (ii) the wages tax;
    • (iii) the tak on income from literary and artistic activities;
    • (iv) the agricultural tax;
    • (v) the tax on population income;
    • (vi) the house tax; and
    • (vii) the capital tax;
  • (hereinafter referred to as “Czechoslovak tax”)
  • (b) in Norway:
    • (i) the national, the county municipal and municipal taxes on income, including the national contributions to the tax equalization fund and the special tax on income from petroleum exploitation and transportation;
    • (ii) the national and municipal taxes on capital;
    • (iii) the national dues on the profits of non-resident artistes; and
    • (iv) the seamen's tax;
  • (hereinafter referred to as “Norwegian tax”).

(4) This Convention shall also apply 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. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their respective taxation laws.