(a) „licensee“ in the case of the United Kingdom means any person who holds a licence within the meaning of section 12(1) of the Hydrocarbons Taxation Act 1975 or is a party to an agreement or arrangement within the meaning of Schedule 3(5) to the Hydrocarbons Taxation Act 1975 and, in the case of Norway, any person holding a production licence issued by the Norwegian Government for the field concerned; or any other person who, with the consent of the Norwegian Government, owns all or part of the Licensee`s rights, interests and obligations in this area; (2) Taxation of a permanent establishment owned by an enterprise of a Contracting State in the other Contracting State may not be levied less favourably in that other State than taxation levied on companies of that other State carrying on the same activities. 1. Nationals of a Contracting State may not be subject in the other Contracting State to any other taxation or related obligation which is different or more onerous from taxation and to the related requirements to which nationals of that other State are or may be subject in the same circumstances, in particular with regard to residence. General tax treaties between Norway and other countries List of tax treaties, including double taxation treaties, provided by the Norwegian Ministry of Finance. The full text can be downloaded in English for most countries. 2. For the purposes of this Article, „tax claim“ means an amount due on taxes of any kind levied on behalf of the Contracting States or their political divisions or local authorities, to the extent that taxation under this Convention or any other act to which the Contracting Parties are parties does not preclude taxation; as well as interest, administrative penalties and collection or maintenance costs related to this amount. The double taxation agreement entered into force on 17 December 2013. 2. Without prejudice to other provisions of this Convention, the taxation of profits derived from the transport of oil (including gas and other hydrocarbons) from the Murchison field reservoir to and through the terminal, but not from the terminal from profits derived from the disposal of the facilities used for such transport, shall be subject to the principles set out in paragraphs 2 and 4 to the extent referred to in Article 22. 4.

For the purposes of this Article, the term „dividends“ means income from shares or other rights other than claims representing profits and income from other rights of the corporation that are subject to the same tax treatment as income from shares under the laws of the Contracting State in which the distribution company is resident, and also includes all other elements: which is resident under the law of the State in which the company paying the dividends is resident, it is treated as a dividend or distribution of the company. If you are considered a tax resident in two or more countries, it is important to understand possible tax relief through double taxation treaties that wish to enter into an agreement to avoid double taxation and prevent tax evasion with respect to taxes on income and capital; Through our specialized tax databases, we can provide current and historical tax rates, comparative tables and country surveys. We have up-to-date summaries of key facts as well as a detailed analysis of the tax system in jurisdictions around the world, covering corporate, personal, corporate and investment taxation. In addition to Norwegian national regulations, Norway has concluded double taxation treaties with more than 100 countries/jurisdictions in order to avoid double taxation and to enable cooperation between Norway and foreign tax authorities in the application of their respective tax laws. (e) to provide mutual assistance where that State considers that the taxes for which assistance is requested are levied in breach of generally accepted principles of taxation. The following table lists the countries that have concluded a double taxation agreement with the United Kingdom (as of 23 October 2018). On the UK government`s website, there is an up-to-date list of active and historical double taxation treaties. 3. Where, pursuant to paragraph 2 of this Article, a Contracting State adjusts the profits attributable to a permanent establishment of a company of a Contracting State and taxes accordingly the profits of the company which have been taxed in the other State, the other Contracting State shall, to the extent necessary to eliminate double taxation, make an appropriate adjustment if it accepts the adjustment made by the first-mentioned State; If the other Contracting State does not agree, the States Parties shall, by mutual agreement, abolish any resulting double taxation […].