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Application of the MLI to the Tax Treaty between Japan and Norway

  The MLI enters into force for Japan on January 1, 2019, and for Norway on November 1, 2019.
  Based on the reservations and notifications submitted by Japan on September 26, 2018 and by Norway on July 17, 2019, the MLI applies to the tax treaty between Japan and Norway as described below.

1. Tax treaty covered by the MLI
    -“Convention between Japan and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention
      of Fiscal Evasion with respect to Taxes on Income”

      Date of signature: March 4, 1992
      Date of entry into force: December 16, 1992

2. Provisions of the MLI applicable to the tax treaty
    - Article 3(1) (Provisions regarding income derived by or through an entity or arrangement that is treated as
      fiscally transparent)

    - Article 4(1) (Provisions that provide rules for determining whether a person other than an individual shall be treated
      as a resident of one of the Contracting Jurisdictions for the purposes of the tax treaty)

    - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will not
      create opportunities for non-taxation or reduced taxation)

    - Article 6(3) (Preamble language referring to a desire of the Contracting Jurisdictions to develop their economic
      relationship and to enhance their co-operation in tax matters)

    - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the
      principal purposes of any arrangement or transaction was to obtain those benefits)

    - Article 12(1) and (2) (Provisions regarding an agent that is deemed to constitute a permeant establishment)
    - Article 13(2) (Provisions regarding an activity that is deemed not to constitute a permanent establishment even if
      the activity is carried on through a fixed place of business)

    - Article 13(4) (Provisions for combining business activities carried on by closely related persons for the purpose of
      determining whether a permanent establishment exists)

    - Article 15 (Provisions for the definition of a person closely related to an enterprise)
    - Article 16(1), 1st sentence (Provisions for presentation of a case of taxation not in accordance with the provisions
      of the tax treaty for a mutual agreement procedure)

3. Entry into effect
    The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax treaty between Japan and Norway:
    (a) with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving
        rise to such taxes occurs on or after January 1, 2020; and

    (b) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with respect to taxable
        periods beginning on or after May 1, 2020.