TIOL-DDT 516 · Wednesday, 20 December 2006 · story 3 of 5

Avoidance of double taxation and prevention of fiscal evasion with Norway- Tax on royalties reduced to 10%.

The Convention between the Government of the Republic of India and the Kingdom of Norway for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital came into force in the year 1986.

ARTICLE 13 dealing with Royalties and fees for technical services reads as

1. Royalties and fees for technical services arising in a Contracting State and paid to a resident of the other Contracting State may be taxed in that other State.

2. However, such royalties and fees for technical services may also be taxed in the Contracting State in which they arise and according to the laws of that State. But insofar as fees for technical services are considered, to the extent such fees are paid in respect of a contract which is signed after the date of entry into force of this Convention, the tax so charged shall not exceed 20 per cent of such fees. For the purposes of this paragraph, if a lower rate of Indian tax is agreed upon with any other State than Norway after the entry into force of this Convention, such rate shall be applied.

Now this 20 percent is made ten percent.

NOTIFICATION NO. ,Dated : December15, 2006

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