Article 15 Dependent Personal Services 1.Subject to the provisions of Articles 16, 17, 18, 19, 20 and 21, salaries, wages and other similar remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that Contracting state unless the employment is exercised in the other Contracting State. If the employment is so exercised, such remuneration as is derived therefrom may be taxed in that other Contracting State. 2.Notwithstanding the provisions of paragraph 1, remuneration derived by a resident of a Contracting State in respect of an employment exercised in the other Contracting State shall be taxable only in the first-mentioned State if: (a)the recipient is present in the other Contracting State for a period or periods not exceeding in the aggregate 183 days in any period of twelve months; and (b)the remuneration is paid by, or on behalf of, an employer who is not a resident of the other Contracting State; and (c)the remuneration is not borne by a permanent establishment or a fixed base which the employer has in the other Contracting State. 3.Notwithstanding the preceding provisions of this Article, remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting State, may be taxed in the Contracting State in which the place of head office (i. e. Effective management) of the enterprise is situated. Article 16 Directors' Fees 1.Directors' fees and other similar payments derived by a resident of a Contracting State in his capacity as a member of the board of directors or of a similar organ of a company which is a resident of the other Contracting State may be taxed in that other Contracting State. 2.Salaries, wages and other similar remuneration derived by a resident of a Contracting State in his capacity as an official in a top-level managerial position of a company which is a resident of the other Contracting State may be taxed in that other Contracting State. Article 17 Artistes and Athletes 1.Notwithstanding the provisions of Articles 14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as an athlete, from his personal activities as such exercised in the other Contracting State, may be taxed in that other Contracting state. 2.Where income in respect of personal activities exercised by an entertainer or an athlete in his capacity as such accrues not to the entertainer or athlete himself but to another person, in his capacity as such accrues not to the entertainer or athlete are exercised. 3.Notwithstanding the provisions of paragraphs 1 and 2, income derived by entertainers or athletes who are residents of a Contracting State from the activities exercised in the other Contracting State under a plan of cultural exchange between the Governments of the Contracting States shall be exempt from tax in that other Contracting State. Article 18 Pensions Subject to the provisions of paragraph 2 of Article 19, pensions and other similar remuneration paid to a resident of a Contracting State shall be taxable only in that Contracting State. Article 19 Government Service 1.(a)Remuneration, other than a pension, paid by the Government of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or political subdivision or local authority thereof, in the discharge of functions of a governmental nature, shall be taxable only in that Contracting State. (b)However, such remuneration shall be taxable only in the other Contracting State if the services are rendered in that other Contracting State and the individual is a resident of that other Contracting State who: 　　(i) is a national of that other Contracting State; or (ii)did not become a resident of that other Contracting State solely for the purpose of rendering the services. 　　2.(a)Any pension paid by, or out of funds created by the Government of a Contracting State or a political subdivision or a local authority thereof to an individual in respect of services rendered to the Government of that Contracting State or a political subdivision or a local authority thereof shall be taxable only in that Contracting State. However, in the case such pensions are not taxed in that Contracting State, it may be taxed in the other Contracting State. 　　(b)However, such pension shall be taxable only in the other Contracting State if the individual is a resident of, and a national of, that other Contracting State. 　　3.The provisions of Articles 15, 16, 17 and 18 shall apply to remuneration and pensions in respect of services rendered in connection with a business carried on by the Government of a Contracting State or a political subdivision or a local authority thereof. 　　Article 20 Teachers and Researchers 1.An individual who is, or immediately before visiting a Contracting State was, a resident of the other Contracting State and is present in the first-mentioned Contracting State for the primary purpose of teaching, giving lectures or conducting research at a university, college, school or educational institution or scientific research institution accredited by the Government of the first-mentioned State shall be exempt from tax in the first-mentioned Contracting State, for a period not exceeding three years from the date of his first arrival in the first-mentioned Contracting State, in respect of remuneration for such teaching, lectures or research, but only in so far as the remuneration is taxed in that other Contracting State. 　　2.The provision of paragraph 1 shall not apply to income from research if such research is undertaken not in the public interest but primarily for the private benefit of a specific person or persons. 　　Article 21 Students, Apprentices and Trainees 　　1.A student, business apprentice or trainee who is or was immediately before visiting a Contracting State a resident of the other Contracting State and who is present in the first-mentioned State solely for the purpose of his education or training shall be exempt from tax in that Contracting State on: (a)payments received from abroad for the purpose of his maintenance, education or training; 　　(b)scholarships, grants, allowances, and awards from governmental, charitable, scientific, literary or educational organizations for the purposes of his maintenance, education or training. 　　2.In respect of remuneration from employment, a student, business apprentice or trainee described in paragraph 1 shall be entitled during such education or training to the same exemptions, reliefs or reductions in respect of taxes available to residents of the State which he is visiting. 　　Article 22 Other Income 1.Items of income of a resident of a Contracting State, wherever arising, not dealt with in the foregoing Articles of this Agreement shall be taxable only in that Contracting State. 　　2.The provisions of paragraph 1 shall not apply to income, other than income from immovable property as defined in paragraph 2 of Article 6, if the recipient of such income, being a resident of a Contracting State, carries on business in the other Contracting State through a permanent establishment situated therein, or performs in that other Contracting State independent personal services from a fixed base situated therein, and the right or property in respect of which the income is paid is effectively connected with such permanent establishment or fixed base. In such case the provisions of Article 7 or Article 14, as the case may be, shall apply. 　　3.Notwithstanding the provisions of paragraphs 1 and 2, items of income of a resident of a Contracting State not dealt with in the foregoing Articles of this Agreement and arising in the other Contracting State may be taxed in that other Contracting State. 　　Article 23 Offshore Activities 1.The provisions of this Article shall have effect notwithstanding any other provision of this Agreement. 　　2.In this Article the term "offshore activities" means activities which are carried on offshore in connection with the exploration or exploitation of the seabed and subsoil and their natural resources situated in a Contracting State. 　　3.A person who is a resident of a Contracting State and carries on offshore activities in the other Contracting State shall, subject to paragraphs 4 and 5 of this Article, be deemed in relation to those activities to be carrying on business in that other Contracting State through a permanent establishment or fixed base situated therein. 　　4.The provisions of paragraph 3 shall not apply where the activities are carried on for a period not exceeding 30 days in the aggregate in any twelve months period. However, for the purpose of this paragraph the days referred to shall be calculated in the aggregate as follows: (a)activities carried on by an enterprise associated with another enterprise shall be regarded as carried on by the enterprise with which it is associated if the activities in question are substantially the same as those carried on by the last-mentioned enterprise; 　　(b)two enterprises shall be deemed to be associated enterprises if one is controlled directly or indirectly by the other enterprise, or both are controlled directly or indirectly by third persons. 　　5.Paragraph 3 of this Article shall not apply where a resident of a Contracting State carries on transportation of supplies or personnel to a location, or between locations, where offshore activities are being carried on in the other Contracting State, or operate tugboats and other vessels auxiliary to such activities. 　　6.(a)Subject to sub-paragraph (b) of this paragraph, salaries, wages and similar remuneration, however paid, derived by a resident of a Contracting State in respect of an employment connected with offshore activities in the other Contracting State may, to the extent that the duties are performed offshore in that other Contracting State, be taxed in that other Contracting State provided that the employment offshore is carried on for a period exceeding 30 days in the aggregate in any twelve months period. 　　(b)Sub-paragraph (a) of this paragraph shall not apply to salaries, wages and similar remuneration derived by a resident of a Contracting State in respect of an employment exercised aboard a ship or aircraft engaged in the transportation of supplies or personnel to a location, or between locations, where offshore activities are being carried on in the other Contracting State, or in respect of an employment exercised aboard tugboats or other vessels operated auxiliary to such activities. 　　7.Gains derived by a resident of a Contracting State from the alienation of: (a)exploration or exploitation rights, or 　　(b)property situated in the other Contracting State and used in connection with the exploration or exploitation of the sea-bed and subsoil and their natural resources situated in that other Contracting State, or 　　(c)shares deriving their value or the greater part of their value directly or indirectly from such rights or such property or from such rights and such property taken together may be taxed in that other Contracting State. In this paragaph "exploration or exploitation rights" means rights to assets to be produced by the exploration or exploitation of the sea-bed and subsoil and their natural resources in the other Contracting State, including rights to interests in or to the benefit of such assets. 　　Article 24 Capital 1.Capital represented by immovable property referred to in Article 6, owned by a resident of a Contracting State and situated in the other Contracting State may be taxed in that other Contracting State. 　　2.Capital represented by movable property forming part of the business property of a permanent establishment which an enterprise of a Contracting State has in the other Contracting State, or by movable property pertaining to a fixed base available to a resident of a Contracting State in the other Contracting State for the purpose of performing independent personal services, may be taxed in that other Contracting State. 　　3.Capital represented by ships and aircraft operated in international traffic and by movable property pertaining to the operation of such ships and aircraft shall be taxable only in the Contracting State in which the place of head office (i. e. Effective management) of the enterprise is situated. 　　4.All other elements of capital of a resident of a Contracting State shall be taxable only in that Contracting State. 　　Article 25 Methods for the Elimination of Double Taxation 1.In China, double taxation shall be eliminated as follows: (a)Where a resident of China derives income from Norway, the amount of tax on that income payable in Norway in accordance with the provisions of this Agreement, may be credited against the Chinese tax imposed on that resident. The amount of credit, however, shall not exceed the amount of the Chinese tax on that income computed in accordance with the taxation laws and regulations of China. 　　(b)Where the income derived from Norway is a dividend paid by a company which is a resident of Norway to a company which is a resident of China and which owns not less than 10 per cent of the shares of the company paying the dividend, the credit shall take into account the tax paid to Norway by the company paying the dividend in respect of its income. 　　2.In Norway, double taxation shall be eliminated as follows: (a)Where a resident of Norway derives income or owns capital which, in accordance with the provisions of this Agreement, may be taxed in China, Norway shall, subject to the provisions of sub-paragraphs (b), (c) and (d), exempt such income or capital from tax. 　　(b)Where a resident of Norway derives items of income which, in accordance with the provisions of Articles 10, 11, 12, 16, paragraph 3 of Article 22 and Article 23 may be taxed in China. Norway shall allow as a deduction from the tax on the income of that person an amount equal to the tax paid in China. Such deduction shall not, however, exceed that part of the tax, as computed before the deduction is given, which is attributable to such items of income derived from China. 　　(c)For the purposes of sub-paragraph (b) and in respect of the items of income referred to in Articles 10, 11 and 12 the amount of Chinese tax levied shall be deemed to be equal to 15 per cent of the gross dividends, 10 per cent of the gross interest and 20 per cent of the gross royalties. 　　The provisions of this sub-paragraph shall apply only for the first ten years for which this Agreement is effective. This period may be extended by mutual agreement between the competent authorities of the Contracting States, 　　(d)Where in accordance with any provision of this Agreement income derived or capital owned by a resident of Norway is exempt from tax in Norway, Norway may nevertheless, in calculating the amount of tax on the remaining income or capital of such resident, take into account the exempted income or capital. 　　Article 26 Non-Discrimination 1.Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other or more burdensome than the taxation and connected requirements to which nationals of that other Contracting State in the same circumstances are or may be subjected. The provisions of this paragraph shall, notwithstanding the provisions of Article 1, also apply to persons who are not residents of one or both of the Contracting States. 　　2.The taxation on a permanent establishment which an enterprise of a Contracting State has in the other Contracting State shall not be less favourably levied in that other Contracting State than the taxation levied on enterprises of that other Contracting State carrying on the same activities. The provisions of this paragraph shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents. 　　3.Except where the provisions of Article 9, paragraph 7 of Article 11, or paragraph 6 of Article 12, apply, interest, royalties and other disbursements paid by an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable profits of such enterprise, be deductible under the same conditions as if they had been paid to a resident of the first-mentioned State. Similarly, and debts of an enterprise of a Contracting State to a resident of the other Contracting State shall, for the purpose of determining the taxable capital of such enterprise, be deductible under the same conditions as if they had been contracted to a resident of the first-mentioned State. 　　4.Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first-mentioned State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. 　　5.The provisions of this Article shall, notwithstanding the provisions of Article 2, apply to taxes of every kind. 　　Article 27 Mutual Agreement Procedure 1.Where a person considers that the actions of one or both of the Contracting States result or will result for him in taxation not in accordance with the provisions of this Agreement, he may, irrespective of the remedies provided by the domestic law of those States, present his case to the competent authority of the Contracting State of which he is a resident or, if his case comes under paragraph 1 of Article 26, to that of the Contracting State of which he is a national. The case must be presented within three years from the first notification of the action resulting in taxation not in accordance with the provisions of the Agreement. 　　2.The competent authority shall endeavour, if the objection appears to it to be justified and if it is not itself able to arrive at a satisfactory solution, to resolve the case by mutual agreement with the competent authority of the other Contracting State, with a view to the avoidance of taxation which is not in accordance with the provisions of this Agreement. Any agreement reached shall be implemented notwithstanding any time limits in the domestic law of the Contracting States. 　　3.The competent authorities of the Contracting States shall endeavour to resolve by mutual agreement any difficulties or doubts arising as to the interpretation or application of the Agreement. They may also consult together for the elimination of double taxation in cases not provided for in this Agreement. 　　4.The competent authorities of the Contracting States may communicate with each other directly for the purpose of reaching an agreement in the sense of paragraphs 2 and 3. When it seems advisable for reaching agreement, representatives of the competent authorities of the Contracting States may meet together for an oral exchange of opinions. 　　Article 28 Exchange of Information 1.The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Agreement or of the domestic laws of the Contracting States concerning taxes covered by the Agreement insofar as the taxation thereunder is not contrary to this Agreement, in particular for the prevention of evasion of such taxes. The exchange of information is not restricted by Article 1. Any information received by a Contracting State shall be treated as secret and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in relation to, the taxes covered by the Agreement. Such persons or authorities shall use the information only for such purposes. They may disclose the information in public court proceedings or in judicial decisions. 　　2.In no case shall the provisions of paragraph 1 be construed so as to impose on a Contracting State the obligation: (a)to carry out administrative measures at variance with the laws and administrative practice of that Contracting State or of the other Contracting State; 　　(b)to supply information which is not obtainable under the laws or in the normal course of the administration of that Contracting State or of the other Contracting State; 　　(c)to supply information which would disclose any trade, business, industrial, commercial or professional secret or trade process, or information, the disclosure of which would be contrary to public policy (ordre public). 　　Article 29 Diplomatic Agents and Consular Officers 　　Nothing in this Agreement shall affect the fiscal privileges of diplomatic agents or consular officers under the general rules of international law or under the provisions of special agreements. 　　Article 30 Entry into Force 　　This Agreement shall enter into force on the thirtieth day after the date on which diplomatic notes indicating the completion of internal legal procedures necessary in each country for the entry into force of this Agreement have been exchanged. This Agreement shall have effect as respects income or capital relating to the taxable years beginning on or after the first day of January next following that in which this Agreement enters into force. 　　Article 31 Termination 　　This Agreement shall continue in effect indefinitely but either of the Contracting States may, on or before the thirtieth day of June in any calendar year beginning after the expiration of a period of five years from the date of its entry into force, give written notice of termination to the other Contracting State through the diplomatic channel. In such event this Agreement shall cease to have effect as respects income or capital relating to the taxable years beginning on or after the first day of January in the calendar years next following that in which the notice of termination is given. 　　DONE at Beijing on the 25th day of February 1986, in duplicate in the Chinese, Norwegian and English languages, the three texts being equally authentic. In case of any divergence of interpretation between the Chinese and Norwegian texts, the English text shall prevail. For the Government of the People's For the Government of the Republic of China Kingdom of Norway