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6.2 Double tax relief

Commentary

6.2 Double tax relief | Norway

Norway

The general rule in most countries is that the country in which income is sourced has the first right to tax that income. Earnings are sourced in the country or countries in which an employee physically performs their employment duties, so the place where an employee works has superior taxing rights over the country of residence or citizenship.

Double tax relief is offered though many of Norway's tax treaties. Some of the articles of the Russian treaty have been suspended (Gov.ru). There are also complications in regards to a denouncement in February 2024 of the Norway and Netherlands treaty, see Overheid.nl for further details.

Model articles for double tax treaties have been developed by the OECD, but the provisions in each specific treaty can vary considerably. The OECD also provides latitude to treaty countries on how treaties are operated in practice. The result is that apparently standard provisions may be applied by certain countries differently to other countries, so in any employment situation involving Norway, the terms of each specific

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