Article 5. BUSINESS PROFITS
U.S. Income Tax Treaty — Norway Technical Explanation 1971 508 Compliant · 2026-10-03 edition · updated 2026-10-04 · United States
This article sets forth the typical treaty rule that industrial or commer cial profits of a resident of one State are taxable in the other State only if the resident has a permanent estab lishment in that other State. Where there is a permanent establishment only the profits attributable to the permanent establishment can be taxed by that other State. For purposes of
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