24 FIRST SCHEDULE AGREEMENT BETWEEN THE GOVERNMENT OF THE UNITED KINGDOM AND THE NORWEGIAN GOVERNMENT FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME. The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of Norway, Desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income, Have agreed as follows:- ARTICLE I. (1) The taxes which are the subject of the present Convention are:- (a) In Norway: The national income tax, including the national defence tax on income, the communal income tax, the old age pension tax, the war pension tax, and the seamen's tax, and, for the purposes of Article XIX, the national property tax, including the national defence tax on property (hereinafter referred to ns "Norwegian tax"); (b) In the United Kingdom of Great Britain and Northern Ireland: The income tax (including surtax) and the profits tax (hereinafter re- ferred to as "United Kingdom tax"). (2) The present Convention shall also apply to any other taxes of a substan- tially similar character imposed in Norway or the United Kingdom subsequently to the date of signature of the present Convention. ARTICLE II. (1) In the present Convention, unless the context otherwise requires:- (a) The term "United Kingdom" means Great Britain and Northern Ireland, excluding the Channel Islands and the Isle of Man; (b) The term "'Norway" means the Kingdom of Norway, excluding Spits- bergen and Bear Ildand and Jan Mayen and the Norwegian dependencies outside Europe; (c) The terms "one of the territories" and "the other territory" mean the United Kingdom or Norway, as the context requires; - (d) The tern "tax" means United Kingdom tax or Norwegian tax, as the context requires; (e) The term "person" includes any body of persons, corporate or not cor- porate; (f) The term "company'" means any body corporate; (n-) The terms "resident of the United Kingdom" and "resident of Norway" mean respectively any person who is. resident in the United Kingdom ::r ,he purposes of United Kingdom tax and not resident in Norway for the purposes of Norwegian tax, and any person who is resident in Norway ifor the purposes of Norwegian tax and not resident in the United King- dom for the purposes of United Kingdom tax; a company shall be regarded as resident in the United Kingdom if its business is managed and con- trolled in the United Kingdom and as resident in Norway if its business is mariaged or controlled in Norway;