Norway has 84 tax agreements in force, as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with Denmark, the Faroe Islands, Finland, Iceland and Sweden (the “Nordic Convention”).1 Twenty-six of those agreements, including the Nordic Convention, comply with the minimum standard.
Norway signed the MLI in 2017 and deposited its instrument of ratification on the 17 July 2019, listing 28 of its agreements in force at that time. The MLI entered into force for Norway on 1 November 2019. The agreements modified by the MLI come into compliance with the minimum standard once the provisions of the MLI take effect.
Norway has not listed its agreements with Albania, Austria, Azerbaijan, Barbados, Benin, Bosnia-Herzegovina, Canada, Côte d’Ivoire, Croatia, Curaçao, Egypt, France, Germany, Greenland, Hungary, Indonesia, Israel, Italy, Jamaica, Kazakhstan, Kenya, Korea, Malaysia, Montenegro, Morocco, New Zealand, North Macedonia, Pakistan, Qatar, Senegal, Sierra Leone, Singapore, the Slovak Republic, Spain, Sri Lanka, Switzerland, Thailand, Tunisia, Ukraine, Viet Nam and Zambia to be covered under the MLI. These agreements will therefore not, at this stage, be modified by the MLI. Albania, Barbados, Bosnia-Herzegovina, Canada, Côte d’Ivoire, Croatia, Curaçao, Egypt, France, Hungary, Indonesia, Israel, Italy, Jamaica, Kazakhstan, Kenya, Korea, Malaysia, Morocco, New Zealand, North Macedonia, Pakistan, Senegal, Singapore, the Slovak Republic, Tunisia, Ukraine and Viet Nam have listed their agreements with Norway under the MLI.
Norway indicated in its response to the Peer Review questionnaire that steps have been taken (other than under the MLI) to implement the minimum standard in its agreements with Austria, Canada, France, Germany, Greenland, Israel, Italy, Korea, Malaysia, New Zealand, Pakistan, Qatar, Singapore, Slovak Republic, Spain, Thailand and the United States.
Norway has signed a bilateral complying instrument with respect to its agreement with Belgium, Brazil and Ghana*.
Norway indicated in its response to the Peer Review questionnaire that the agreements with Azerbaijan, Bangladesh*, Gambia*, Malawi*, Nepal*, Uganda*, Venezuela*, and Zimbabwe* do not give rise to material treaty-shopping concerns for Norway.
Norway is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2