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ARTICLE 20

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

Investment or Holding Companies

A corporation of one of the Contracting States deriving dividends, interest, royalties, or capital gains from sources within the other Contracting State shall not be entitled to the benefits of Articles 8 (Dividends), 9 (Interest), 10 (Royalties) or 12 (Capital Gains) if (a) By reason of special measures the tax imposed on such corporation by the first-mentioned Contracting State with respect to such dividends, interest, royalties, or capital gains is substantially less than the tax generally imposed by such Contracting State on corporate profits, and

(b) 25 percent or more of the capital of such corporation is held of record or is otherwise determined, after consultation between the competent authorities of the

Contracting States, to be owned directly or indirectly, by one or more persons who are not individual residents of the first-mentioned Contracting State (or, in the case of a Norwegian corporation, who are citizens of the United States).

CHAPTER IV TAXATION OF CAPITAL

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▸Contents — U.S. Income Tax Treaty — Norway Income Tax Treaty - 1971
U.S. Income Tax Treaty — Norway Income Tax Treaty - 1971

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