Treaty Series Recueil des Traitds - United Nations Treaty Collection

1967 Nations Unies - Recueil des Traitds 337
Continental Shelf, as an area within which the rights of the Kingdom of Norway
with respect to the sea bed and sub-soil and their natural resources may be
exercised; the term does not comprise Spitsbergen (including Bear Island),
Jan Mayen and the Norwegian dependencies outside Europe."
Article III
The second sentence of paragraph (1) of Article XVI of the Convention (which
sentence begins with the words " Where such income is an ordinary dividend "
and ends with the words " the dividend exceeds that fixed rate ") shall be deleted
and the following substituted :
" Where such income is a dividend paid by a company resident in Norway
to a company resident in the United Kingdom which controls directly or
indirectly not less than one-tenth of the voting power in the former company,
the credit shall take into account (in addition to any Norwegian tax payable
in respect of the dividend) the Norwegian tax payable by that former company
in respect of its profits. "
Article IV
The third sentence of paragraph (2) of Article XVI of the Convention (which
sentence begins with the words " Where such income is an ordinary dividend "
and ends with the words " the dividend exceeds that fixed rate ") shall be deleted
and the following substituted:
" Where such income is a dividend paid by a company resident in the
United Kingdom to a company resident in Norway which controls directly
or indirectly not less than one-tenth of the voting power in the former company,
the deduction, in the event that it is restricted to the amount of the United
Kingdom tax, shall take into account (in addition to any United Kingdom
tax payable in respect of the dividend) the United Kingdom tax payable by
that former company in respect of its profits.
Article V
(1) This Protocol shall be ratified and the instruments of ratification shall
be exchanged at Oslo as soon as possible.
(2) This Protocol shall enter into force after the expiration of a month following
the date on which the instruments of ratification are exchanged. It shall
thereupon be regarded as an integral part of the Convention and shall have effect
as follows. Articles I and II shall have effect from 6th April, 1966, or the date of
entry into force of this Protocol, whichever is the later. Articles III and IV shall
have effect in relation only to dividends payable on or after 6th April, 1966, or on
or after the date of entry into force of this Protocol, whichever is the later.
IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed
this Protocol.
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