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The Double Taxation Relief (Taxes on Income) (Norway) Order 2000
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(8) Gains derived by a resident of a Contracting State from the alienation of:
(a)exploration or exploitation rights; or
(b)property situated in the other Contracting State and used in connection with offshore activities, as defined in paragraph (2) of this Article, carried on in that other State; or
(c)shares deriving their value or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together;
may be taxed in that other State. In this paragraph “exploration or exploitation rights” means rights to assets to be produced by the exploration or exploitation of the seabed and subsoil and their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets.
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