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Article 7. RELATED PERSONS

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

This article complements section 482 of the Internal Revenue Code of 1954 and confirms the power of each government to allocate items of in­ come, deduction, credit, or allowance in cases in which a resident of one State is related to any other person if such related persons impose conditions between themselves which are differ­ ent from conditions which would be imposed between independent persons. A similar provision is contained in the OECD Model Convention.

Provision is made in Article 27 (Mutual Agreement Procedure) for consultation and agreement between the two States where an allocation by either State results or would result in double taxation.

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▸Contents — U.S. Income Tax Treaty — Norway Technical Explanation 1971 508 Compliant
U.S. Income Tax Treaty — Norway Technical Explanation 1971 508 Compliant

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