Australian Tax Treaties
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (the MLI) has modified the application of this tax treaty. A synthesised text of the MLI and this tax treaty is available to facilitate the understanding of how the MLI modifies this tax treaty.
The existing taxes to which this Convention shall apply are:
(a) in the case of Australia:
(i) the income tax; and
imposed under the federal law of Australia;
(ii) the resource rent tax in respect of offshore projects relating to exploration for or exploitation of petroleum resources,
(b) in the case of Norway:
(i) the tax on general income;
(ii) the tax on personal income;
(iii) the special tax on petroleum income;
(iv) the resource rent tax on income from production of hydro-electric power;
(v) the withholding tax on dividends; and
(vi) the tax on remuneration to non-resident artistes, etc.
(2)
This Convention shall apply also to any identical or substantially similar taxes that are imposed under the federal law of Australia or the law of Norway after the date of signature of this Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes that have been made in the law of their respective States relating to the taxes to which this Convention applies within a reasonable period of time after those changes.
(3)
For the purposes of Article 24, the taxes to which this Convention shall apply are taxes of every kind and description imposed on behalf of the Contracting States, or their political subdivisions or local authorities.
(4)
For the purposes of Articles 26 and 27, the taxes to which this Convention shall apply are:
(a) in the case of Australia, taxes of every kind and description imposed under the federal tax laws administered by the Commissioner of Taxation; and
(b) in the case of Norway, taxes of every kind and description.
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