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Article 21. CAPITAL TAXES

U.S. Income Tax Treaty — Norway Technical Explanation 1971 508 Compliant · 2026-10-03 edition · updated 2026-10-04 · United States

The existing Convention does not contain an article relative to capital taxes since they are not one of the taxes covered by the Convention. The proposed Convention provides, on a reciprocal basis, that a resident of one State shall be exempt from capital tax by the other State on all nonbusiness property (excluding real property) and on property (other than real property referred to in Article 11 (In­ come from Real Property)) pertain­ ing to the operation of ships and air­ craft.

Since the United States does not impose a separate capital (net wealth) tax, this article represents a unilateral concession by Norway. In the absence of a convention, individu­ als who are not residents of Norway would, nevertheless, be subject to the municipal capital tax with respect to their net wealth situated in Norway. The minimum rate is 0.4 percent and the maximum rate is 1.0 percent but the municipal districts in Norway apply the maximum rate. Since 1969, there has been no national capital tax in Norway.

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