Canada-Norway Income Tax Convention - Agreement between Competent Authorities

New Competent Authority Agreement Regarding the Professors and Teachers Article

Under Article 18 - Professors and Teachers of the 1966 Canada-Norway Income Tax Convention (1966 Convention), teachers who were resident in one of the Contracting States and who met certain other conditions, were not subjected to tax in the other State on remuneration from their teaching in that other State. The new Canada-Norway Income Tax Convention (2002 Convention), which came into force on December 19, 2002, does not have a Professors and Teachers Article.

Teachers who had signed contracts to teach in the other State prior to the coming into force of the 2002 Convention may have been influenced by the treatment under the 1966 Convention at the time they signed their contracts, and may be disadvantaged under the rules of the 2002 Convention.

The Competent Authorities of Canada and Norway have agreed that, upon the specific request of a taxpayer, the CRA and the Norwegian Directorate of Taxes will continue to apply the provisions of Article 18 of the 1966 Convention in situations where a resident of either Contracting State entered into a teaching contract with a resident of the other State prior to the coming into force of the 2002 Convention.

Visiting teachers should address specific requests under this agreement to the local tax services office.