The Double Taxation Relief (Taxes on Income) (Norway) Order 2000

PART II EXCHANGE OF NOTES

London

12th October 2000

Excellency

I have the honour to refer to the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital which has been signed today and to make on behalf of the Government of the United Kingdom the following proposal:

Where, under the terms of paragraph (6) of Article 10, paragraph (5) of Article 11, paragraph (5) of Article 12 or paragraph (5) of Article 21 of this Convention, the provisions of the Article in question do not apply to an item of income, then that income may be taxed in both Contracting States in accordance with the domestic law of each State.

If the foregoing proposal is acceptable to the Goverenment of the Kingdom of Norway, I have the honour to suggest that the present Note and Your Excellency’s reply to that effect should be regarded as constituting an agreement between the two Governments in this matter, which shall enter into force at the same time as the entry into force of the Convention.

I avail myself of this opportunity to extend to Your Excellency the assurance of my highest consideration.

Stephen C Timms

London

12th October 2000

Excellency

I have the honour to acknowledge receipt of Your Excellency’s Note of today which reads as follows:

“I have the honour to refer to the Convention between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and Capital which has been signed today and to make on behalf of the Government of the United Kingdom the following proposal:

Where, under the terms of paragraph (6) of Article 10, paragraph (5) of Article 11, paragraph (5) of Article 12 or paragraph (5) of Article 21 of this Convention, the provisions of the Article in question do not apply to an item of income, then that income may be taxed in both Contracting States in accordance with the domestic law of each State.

If the foregoing proposal is acceptable to the Government of the Kingdom of Norway, I have the honour to suggest that the present Note and Your Excellency’s reply to that effect should be regarded as constituting an agreement between the two Governments in this matter, which shall enter into force at the same time as the entry into force of the Convention.”

The foregoing proposals being acceptable to the Government of the Kingdom of Norway, I have the honour to confirm that Your Excellency’s Note and this reply shall be regarded as constituting an agreement between the two Governments in this matter which shall enter into force at the same time as the entry into force of the Convention.

I take this opportunity to renew to Your Excellency the assurances of my highest consideration.

Tarald O Brautaset