Convention between the Kingdom of Spain and the Kingdom of Norway for the avoidance of double taxation and the prevention of fiscval evasion with respect to taxes on income and on capital
| Coming into Force | 18 December 2000 |
| Subject Terms | Taxation |
| Date of Conclusion | 06 October 1999 |
| Registration Date | 18 May 2001 |
| Registration Number | 37497 |
| Type of Document | Bilateral |
| Participants | Noruega,España |
| Party Submitting the Application for Registration | Spain |
No.
37497
Spain
and
Norway
Convention
between
the
Kingdom
of
Spain and the
Kingdom
of
Norway
for
the
avoidance
of
double
taxation
and
the prevention
of
fiscal
evasion
with
respect to
taxes on
income
and
on
capital
(with
protocol).
Madrid,
6
October
1999
Entry
into
force:
18
December
2000
by
the
exchange
of
instruments
of
ratification,
in
accordance
with
article
29
Authentic
texts:
English,
Norwegian
and
Spanish
Registration
with the
Secretariat
of
the United
Nations:
Spain,
18
May 2001
Espagne
et
Norve'ge
Convention
entre
le
Royaume
d'Espagne
et
le
Royaume
de
Norv~ge
tendant
A
6viter
la
double
imposition
et
i
pr6venir
l'6vasion
fiscale
en
mati~re
d'impbts
sur
le
revenu
et
sur
la
fortune
(avec
protocole).
Madrid,
6
octobre
1999
Entr6e
en
vigueur
:
18
d~cembre
2000
par
6change
des
instruments
de
ratification,
conform
ment
6
Particle
29
Textes
authentiques
:
anglais,
norv~gien
et espagnol
Enregistrement
aupr~s
du
Secretariat
des
Nations
Unies
:
Espagne,
18
mai 2001
Volume
2148,
1-37497
[
ENGLISH
TEXT
-
TEXTE
ANGLAIS
]
CONVENTION
BETWEEN
THE
KINGDOM
OF
SPAIN
AND THE
KINGDOM
OF
NORWAY
FOR
THE
AVOIDANCE
OF
DOUBLE TAXATION
AND
THE
PREVENTION
OF
FISCAL EVASION WITH
RESPECT
TO
TAXES
ON
INCOME
AND
ON
CAPITAL
The
Government
of
the
Kingdom
of
Spain
and
the
Government
of
the
Kingdom
of
Norway desiring to
conclude
a
Convention for
the
Avoidance
of
Double
Taxation
and
the
Prevention
of
Fiscal Evasion
with respect
to
taxes
on
income
and
on
capital,
have
agreed
as
follows:
Article
1.
Persons
Covered
This
Convention
shall
apply
to
persons who
are
residents
of
one
or
both
of
the
Con-
tracting
States.
Article
2.
Taxes
Covered
1.
This
Convention
shall
apply
to
taxes on
income
and
on
capital
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
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
in
particular:
a)
in
Norway:
(i)
the
national tax
on income
(inntektsskatt
til
staten);
(ii)
the
county municipal
tax on income
(inntektsskatt
til fylkeskommunen);
(iii)
the
municipal tax
on
income
(inntektsskatt
til kommunen);
(iv)
the
national
tax
on
capital
(formuesskatt til staten);
(v)
the
municipal
tax on capital
(formuesskatt
til
kommunen);
(vi) the
national tax
relating
to
income
and
capital from
the
exploration
for
and the
ex-
ploitation
of
submarine petroleum
resources
and
activities and work
relating
thereto,
in-
cluding
pipeline transport
of
petroleum
produced
(skatt
til
staten
vedrorende
inntekt
og
formue
i
forbindelse
med
undersokelse
etter
og
utnyttelse
av
undersjoiske
petroleums-
forekomster
og
dertil
knyttet virksomhet
og
arbeid,
herunder rorledningstransport
av
utvunnet
petroleum);
and
Volume
2148,
1-37497
(vii) the
national
tax
on
remuneration
to
non-resident
artistes (lov
om
skatt
pa
honorar-
er
som
tilfaller
kunstnere
bosatt
i
utlandet)
(hereinafter
referred to
as
"Norwegian
tax");
b)
in
Spain:
(i)
the income
tax
on
individuals
(Impuesto
sobre
la
Renta
de
las
Personas Fisicas);
(ii)
the
corporation
tax
(Impuesto
sobre
Sociedades);
(iii)
the
capital
tax
(Impuesto
sobre
el
Patrimonio);
and
(iv)
local
taxes on income
and
on
capital
(Impuestos
locales sobre
la
Renta
y
el
Patri-
monio)
(hereinafter
referred to
as
"Spanish
tax").
4.
The
Convention
shall
apply
also
to
any identical or
substantially
similar
taxes
which
are
imposed
by
either Contracting
State
after
the
date
of
signature
of
the
Convention
in
ad-
dition
to,
or
in
place
of,
the
existing
taxes.
Article
3.
General
Definitions
1.
For
the
purposes
of
this
Convention,
unless
the
context otherwise requires:
a)
the
term
"Norway"
means
the
territory
of
the
Kingdom
of
Norway,
including any
area
outside
the
territorial
sea
upon
which,
in
accordance
with international
law
and
in ap-
plication
of
its
legislation,
the
Kingdom
of
Norway
exercises
or
may
in the
future
exercise
jurisdiction
or
sovereign
rights;
the
term
does
not
comprise Svalbard, Jan
Mayen and
the
Norwegian
dependencies
("biland");
b)
the
term
"Spain"
means
the
territory
of
the
Kingdom
of
Spain,
including
any
area
outside
the
territorial
sea
upon
which,
in
accordance
with international law
and
in
applica-
tion
of
its
legislation,
the
Kingdom
of
Spain
exercises
or
may
in
the
future
exercise
juris-
diction
or
sovereign rights;
c)
the
terms
"a
Contracting
State"
and
"the
other
Contracting
State"
mean Norway
or
Spain
as
the
context requires;
d)
the
term
"person"
comprises an
individual,
a
company
and
any
other body
of
per-
sons;
e)
the
term "company" means any
body
corporate
or
any entity
which
is
treated
as
a
body
corporate
for
tax
purposes;
f)
the
terms
"enterprise
of
a
Contracting
State"
and "enterprise
of
the
other
Contracting
State"
mean respectively
an
enterprise carried
on
by
a
resident
of
a
Contracting
State and
an
enterprise
carried
on
by
a
resident
of
the
other
Contracting
State;
g)
the
term "international
traffic"
means
any
transport
by
a
ship
or
aircraft operated
by
an
enterprise
of
a
Contracting
State,
except
when
the ship
or
aircraft
is
operated
solely be-
tween
places in
the
other
Contracting
State;
h)
the
term "competent
authority"
means:
(i)
in
Norway,
the
Minister
of
Finance
and
Customs
or his
authorized representative;
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