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Norway; Slovenia

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Treaty between Norway and Slovenia – details

Details of the income tax treaty and protocol between Norway and Slovenia, signed on 18 February 2008, have become available. The treaty generally applies from 1 January 2010 and replaces the former Yugoslavia-Norway income and capital tax treaty and protocol of 1 September 1983 in relations between Slovenia and Norway. The treaty was concluded in the Slovenian, Norwegian and English languages, each text having equal authenticity. In the case of divergence, however, the English text prevails. The treaty generally follows the OECD Model Convention.

The maximum rates of withholding tax are:

-   15% on dividends in general; 0% if the beneficial owner is (i) a company holding directly at least 15% of the capital of the company paying the dividends or (ii) in the case of Norway, a resident of Norway who is a partner in a Norwegian partnership and alone or together with other such partners holds directly at least 15% of the capital of the company paying the dividends;
-   5% on interest, subject to exceptions; and
-   5% on royalties.

Deviations from the OECD Model include that:

-   an enterprise performing services in the other contracting state is deemed to have a PE if the services are provided: (i) through an individual who is present in the other contracting state during a period or periods exceeding 183 days in any 12-month period, and more than 50% of the gross revenues attributable to active business activities of the enterprise during this period or periods are derived from the services performed in that other contracting state through that individual; or (ii) during a period or periods exceeding 183 days in any 12-month period, and these services are performed for the same project or for connected projects through one or more individuals who are performing or are present in that other state for performing such services (Art. 5(4)).
However, a PE does not exist if the services as such do not constitute a PE if performed through a fixed place of business because it concerns an activity deemed not to be a PE under Art. 5(5);
-   the treaty includes a provision regarding offshore activities. Under this provision, a person carrying out offshore activities in the other contracting state is deemed to have a PE there if those activities exceed 30 days in the aggregate in any 12-month period (Art. 20);
-   alimony and other maintenance payments to a resident of the other state shall be taxable in the residence state of the recipient. However, such payment shall, to the extent it is not allowable as a relief to the payer, be taxable only in the source state (Art. 17(3));
-   pensions, annuities, and payments under the social security system may be taxed in the residence state of the recipient. In addition, the source state may withhold a tax of 15% on such payment (Art. 17(2)); and
-   the mutual agreement procedure article does not contain a provision for an arbitration procedure (Art. 24).

Both states generally provide for the credit and exemption-with-progression methods to avoid double taxation (Art. 22(1) and (2)).

Neither contracting state can terminate the treaty during a period of 5 years starting from the date of its entry into force (Art. 29).

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