Norway - Employment

Article 15. Dependent personal services

Taxation residence state

1. Subject to the provisions of Articles 16, 17, 18 and 19, salaries, wages and other similar remuneration derived by a resident of one of the States in respect of an employment shall be taxable only in that State unless the employment is exercised in the other State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other State.

Taxation source state

2.   Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of one of the States in respect of an employment exercised in the other State shall be taxable only in the first-mentioned State if:

a)   the recipient is present in that other State for a period or periods not exceeding in the aggregate 183 days in any 12 months’ period; and

b)  the remuneration is paid by, or on behalf of, an employer who is a resident of the State of which the recipient is a resident, and whose business activities do not wholly or almost wholly consist of hiring out of labour; and

c)   the remuneration is not borne by a permanent establishment or a fixed base which the employer has in that other State.

Employment at ship or aircraft

3. Notwithstanding the preceding provisions of this Article, remuneration derived by a resident of one of the States in respect of an employment exercised aboard a ship or aircraft in international traffic or aboard vessels engaged in fishing activities on the high seas shall be taxable only in that State.