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Ireland, Norway Sign Double Taxation Agreement

Robert Lee, Tax-news.com, London

14 December 2000


Last month Ireland signed a double taxation agreement with Norway. Martin Cullen, Irish Minister of State at the Department of Finance and Mrs Liv Mírch Finborud, the Norwegian Ambassador to Ireland, met in Dublin to put their names to a "Convention between Ireland 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". This Convention will replace Ireland's existing double taxation Convention with Norway, which has been in force since 1967 and is one of Ireland's oldest tax conventions.

The Irish Revenue Commissioners said that the new Convention, which reflects the current tax policies of both countries, 'is comprehensive in scope and is largely based on the current OECD Model Convention. It provides for the allocation of taxing rights between the two countries and for relief from double taxation where income or gains remain taxable in both countries. In such cases, credit will be given by the country of residence of the taxpayer for tax paid in the other country.'

The Convention eliminates source taxation of interest and royalty payments and provides for reduced source taxation of dividend payments made between both countries. Other important aspects of the Convention include the non-discrimination provisions, which protect nationals of each country from discriminatory tax provisions in the other, and also the exchange of information provisions, which are necessary to counter tax evasion.

At the signing ceremony, Minister Cullen commented: 'Given the significant trading and investment links which exist between Ireland and Norway, the putting in place of a modern tax treaty is an important contribution to the maintenance and development of these economic relations. Tax treaties represent a vital piece of fiscal infrastructure which allows for the smooth and regulated taxation of cross country business and investment activities.'

The Convention is expected to be ratified by both the Irish and Norwegian governments by the end of 2000 and will enter into force at the beginning of 2001.

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