(1) This Agreement shall apply to persons who, for tax purposes, are deemed to be permanent residents of one or both of the Contracting States.

(2) "A permanent resident of a Contracting State" in this Agreement means:

• (1) In the case of a permanent resident of the USSR: a legal entity or other organization established under the laws of the USSR or of any Union Republic which, for tax purposes, is treated as a legal entity in the USSR, and also an individual who, for tax purposes, is considered to have permanent residence in the USSR;
• (2) In the case of a permanent resident of Norway: a company or any other association which, under the legislation of Norway, is obliged to pay taxes in Norway by reason of the place of management or the fact that the company or association derives its legal status from the legislation in force in Norway, and also an individual who, for tax purposes, is considered to have permanent residence in Norway.

(3) A "permanent resident of both Contracting States" means a person who, in accordance with the tax legislation of one Contracting State, is deemed to be a permanent resident of that Contracting State and who, in accordance with the tax legislation of the other Contracting State, is deemed to be a permanent resident during the same period, of that other Contracting State.

(4) Where, by reason of the provisions of paragraphs (1) to (3) of this Article, an individual is deemed to be a permanent resident of both Contracting States, his status shall be determined as follows:

• (a) He shall be deemed to be a permanent resident of the Contracting State in which he has a permanent home available to him. If he has a permanent home available to him in both Contracting States, he shall be deemed to be a permanent resident of the Contracting State with which his personal and economic relations are closest (centre of vital interests);
• (b) If the Contracting State in which he has his centre of vital interests cannot be determined, or if he does not have a permanent home available to him in either State, he shall be deemed to be a permanent resident of the Contracting State in which he has a habitual abode;
• (c) If he has a habitual abode in both Contracting States or in neither of them, he shall be deemed to be a permanent resident of the Contracting State of which he is a national;
• (d) If both Contracting States regard him as a national, or if he is a national of neither of them, the competent bodies of the Contracting States shall determine by mutual agreement the question of the permanent residence of such an individual for the purposes of this Agreement.

(5) Where by reason of the provisions of paragraphs (1) to (3) of this Article a person other than an individual is deemed to be a permanent resident of both Contracting States, it shall be deemed to be a permanent resident of the State in which its actual management is situated.