{"id":14198,"date":"2021-02-14T18:45:18","date_gmt":"2021-02-14T17:45:18","guid":{"rendered":"https:\/\/melo.no\/?p=14198"},"modified":"2026-06-18T17:41:18","modified_gmt":"2026-06-18T15:41:18","slug":"stater-som-norge-har-skatteavtale-med","status":"publish","type":"post","link":"https:\/\/melo.no\/en\/juridisk-innsikt\/skatt\/stater-som-norge-har-skatteavtale-med\/","title":{"rendered":"What is a tax treaty?"},"content":{"rendered":"
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International double taxation is not prohibited under general international law, nor is it prevented by international law. Nevertheless, there is broad agreement that such double taxation is undesirable. As a result, both national and international rules have been developed to prevent international double taxation.<\/p>\n

National rules aimed at preventing double taxation are found in the domestic legislation of each country. In Norway, these rules are primarily contained in the Tax Act and regulations issued under the Tax Act. International rules for preventing double taxation are found mainly in a broad network of tax treaties.<\/p>\n

Tax treaties are primarily intended to prevent international double taxation<\/h2>\n

Tax treaties are agreements concluded between states, and their primary purpose is to prevent international double taxation. This is achieved by the contracting states mutually limiting or relinquishing their taxing rights with respect to various categories of income.<\/p>\n

From both an international law and constitutional law perspective, tax treaties are considered treaties. They may be either bilateral (concluded between two states) or multilateral (concluded between more than two states). The Nordic Tax Treaty is one of the few examples of a multilateral tax treaty.<\/p>\n

States with which Norway has tax treaties<\/h2>\n

As of today, Norway has entered into tax treaties with more than 90 countries<\/a>. Most of these treaties are based on the same framework as the OECD Model Tax Convention. The OECD Model Tax Convention was first introduced in 1963 and has been revised several times since then. Although the Model Convention is not legally binding on member states, it has nevertheless served as the foundation for the vast majority of tax treaties concluded since 1963.<\/p>\n

What constitutes double taxation?<\/h2>\n

The introduction to the Commentary on the OECD Model Tax Convention defines international double taxation as follows:<\/p>\n

«International juridical double taxation can be generally defined as the imposition of comparable taxes in two (or more) States on the same taxpayer in respect of the same subject matter and for identical periods. (\u2026)»<\/p>\n

Under this definition, international double taxation exists where:<\/p>\n