Treaty detail
United States - Norway tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1971-12-03
Effective
1972-11-29
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 15%
The 1971 Norway treaty does not include a reduced corporate parent-subsidiary rate. The general 15 percent rate applies in both directions, subject to article-level review of beneficial ownership and qualifying status.
Interest
Rate: 0%
The treaty generally provides zero-percent source-country interest withholding. Government, central-bank, and qualifying-institution exceptions apply and require article-level review.
Royalties
Rate: 0%
The treaty generally eliminates source-country withholding on qualifying royalties across the major copyright, patent, and know-how categories.
Permanent establishment
Construction threshold: more than 12 months under the 1971 treaty framework
Dependent-agent analysis under the 1971 wording remains important where a person habitually exercises contracting authority on behalf of the enterprise.
Other treaty flags
The 1971 Norway treaty generally allocates private pensions to the residence state. Government pensions and social-security payments follow distinct article paths and deserve article-level review.
Seeded article summaries
Article 4
Residence
Defines treaty residence under the 1971 treaty framework.
The Norway treaty predates modern limitation-on-benefits drafting, so the residence article carries more of the access-to-benefits work than in newer treaties. Cross-border fact patterns should still be reviewed against domestic-law residence rules.
Article 5
Permanent Establishment
Sets the business-presence threshold for source-country taxation under the 1971 framework.
The Norway treaty follows an older PE construction-and-installation threshold that should be confirmed against the current treaty text. Dependent-agent and preparatory-activity rules remain subject to article-level review.
Article 7
Business Profits
Generally reserves business profits to the residence state absent a permanent establishment in the other state.
This is the operating-rule article once the PE analysis is complete. Under the 1971 framework, the analysis is more textually constrained than in newer treaties, so careful article-level review is important.
Article 10
Dividends
Generally caps source-country dividend withholding at 15 percent, with no reduced parent-subsidiary rate.
The Norway dividend article reflects its 1971 vintage by retaining a single 15 percent rate rather than offering a reduced 5 percent parent-subsidiary rate common in newer treaties.
Article 11
Interest
Generally eliminates source-country withholding on qualifying interest.
Interest under the Norway treaty is generally not subject to source-country withholding. Specific exceptions and beneficial-ownership requirements remain subject to article-level review.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article is one of the clearest practical benefits of the Norway treaty in its current form. The zero-percent result depends on beneficial ownership and falls within the major royalty categories.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CA treaty
- TreatyUS–DE treaty
- TreatyUS–FR treaty
- TreatyUS–JP treaty
- TreatyUS–NL treaty
- TreatyUS–AU treaty
- TreatyUS–KR treaty
Primary sources
- Norway treaty documents pageVerified 2026-05-20
- Official U.S.-Norway treaty PDFVerified 2026-05-20
- IRS Tax Treaty Table 1Verified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.