7 e

(6) Norwegian tax on dividends paid by a company
which 1s a resident of Nor way toa resident of the
United Kingdom, who is subject to tax im the
United Kinydom in respect thereof and does not
earry on trade or business in Norway through
a permanent establishment situated therein, shall not
execed 5 per cent.:

Provided that, where the resident of the
United Kingdom is a company which controls,
directly or indirectly, not less than 50 per cent.
of the entire voting power of the company pay-
ing the dividends, the dividends shall be exempt
from Norwegian tax.

2. Where a company which is a resident of one of the
territories derives profits or income from sources within the
other territory, there shall not be imposed in that other territory
any form of taxation on dividends paid by the company to
persons not resident in that other territory, or any tax in the
vature of an undistributed profits tax on undistributed profits
of the company, whether or not those dividends or undistributed
profits represent, in whole or in part, profits or Income so
derived,

AxticLe VII

1. Any interest or royalty derived from sources within
one of the territories by a resident of the other territory, who
is subject to tex m that other territory in respect thereof and
does not carry on a trade or business in the first-mentioned
territory throngh a permanent establishment situated therein,
shall be exempr from tax in that first-mentioned territory.

2, In this Article—

(a) The term “ interest ” includes interest on bonds,
securities, notes, debentures or on any other form of
indebtedness;

(6) The term “royalty” means any royalty or other

amount paid as consideration for the use of, or for the
privilege of using, any copyrivht, patent, di. ‘sion, secret
process or formula, tr ade mark or other like property, but
does not include any royalty er other amount paid in
respect Of the oper: ation of & mine or quarry or of any
other extraction of natural resources.