ARTICLE 21
U.S. Income Tax Treaty — Norway Income Tax Treaty - 1971 · 2026-10-03 edition · updated 2026-10-04 · United States
Capital Taxes
(1) Capital represented by property referred to in Article 11 (Income from Real Property) may be taxed in the Contracting State in which such property is situated.
(2) Subject to the provisions of paragraph (3) below, capital represented by assets, other than property referred to in paragraph (1), which are effectively connected with a permanent establishment of a resident of one of the Contracting States may be taxed in the Contracting State in which the permanent establishment is situated.
(3) Ships and aircraft of a resident of one of the Contracting States and assets, other than property referred to in paragraph (1), pertaining to the operation of such ships or aircraft shall be exempt from tax by the other Contracting State.
(4) All other elements of capital of a resident of a Contracting State not dealt within this article shall be exempt from tax by the other Contracting State.
CHAPTER V GENERAL RULES
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