Norway
A. Progress in the implementation of the minimum standard
Norway has 84 tax agreements in force, as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with Denmark, the Faroe Islands, Finland, Iceland and Sweden (the “Nordic Convention”).1
Norway signed the MLI in 2017, listing 28 tax agreements.
Norway is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2
The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.
Norway indicated in its response to the Peer Review questionnaire that bilateral negotiations would be used with respect to its agreements with Belgium, Brazil, Canada, France, Germany, Israel, Korea, New Zealand, Singapore, Slovak Republic, Spain, Thailand and the United States.
The Parties to the Nordic Convention signed a complying instrument in 2018.
B. Implementation issues
No jurisdiction has raised any concerns about their agreements with Norway.
Notes
← 1. See the Multilateral convention concluded by Denmark, Finland, the Faroe Islands, Iceland, Norway and Sweden: for the avoidance of double taxation with respect to taxes on income and on capital (1996, 1997, and 2008). In total, Norway identified 88 "agreements" in its List of Tax agreements: 83 bilateral agreements and the Nordic Convention concluded with five of its treaty partners.
← 2. For its agreements listed under the MLI, Norway is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI). Norway stated that while it accepts the application of the PPT under the MLI, it intends where possible to adopt an LOB provision through bilateral negotiation. Norway has also accepted to implement a simplified LOB in agreements concluded with partners that opted in for the simplified LOB under Article 7(7)(a) of the MLI.