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Article 9 - Shipping - Norway (Old - Effective upto 31-3-2012)Extract ARTICLE 9 - Shipping - 1. Profits derived by an enterprise of a Contracting State from the operation of ships in international traffic shall be taxable only in that State. 2. Notwithstanding the provisions of paragraph (1) profits derived from the operation of ships in international traffic may be taxed in the ContractingState in which such operation is carried on; but the tax so charged shall not exceed 50 per cent of the tax otherwise imposed by the internal law of that State. For purposes of this paragraph, the amount of such profits subject to tax in India shall not exceed 7.5 per cent of the sums receivable in respect of the carriage of passengers or freight embarked in India. 3. The provisions of paragraphs (1) and (2) shall also apply to profits derived from the participation in a pool, in a joint business or in an international operating agency. 4. An enterprise shall be deemed to be an enterprise of both Contracting State if (a) the enterprise is carried on by a company or any other body of persons where all the partners are jointly and severally liable and at least one of the partners has unlimited liability ; and (b) at least one of the partners is a resident of one of the Contracting States and one or more of them is a resident of the other Contracting State ; and (c) the effective management of the enterprise is not carried on solely in one of the Contracting States. In that case, the profits of the enterprise, subject to paragraph (2) of this article, shall be taxable in the State where partners mentioned in sub-paragraph (b) are residents in proportion to their part of the profits. The provisions of this paragraph shall not be construed as to grant any benefits to partners resident of a State other than the Contracting States. 5. For the purposes of this article, income from the operation of ships includes income derived from the use, maintenance or rental of containers (including trailers and related equipment for the transport of containers) in connection with the transport of goods or merchandise in international traffic.
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