ARTICLE VI'
 (1) (a) Dividends paid by a company which i4 a resident of the United
Kingdom to a resident of Norway, who is subject to tax in Norway in respect.
thereof and does not carry Qn a trade or business in the United Kingddm through
a permanent establishment situated therein, shall be exempt from United King-
dom surtax. %
 (b) Norwegian tax on dividends paid by a company which is a resident of
Norway to a resident of the United Kingdom, who is subject to tax in the United
Kingdom in respect thereof and does not carry on trade or business in Norway
through a permanent establishment situated therein, shall not exceed 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 paying 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 nature
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.


 ARTICLE 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 tax in that other territory
in respect thereof and does not carry on a trade or business in the first-mentioned
territory through a permanent establishment situated therein, shall-be exempt
from tax in that first-mentioned territory.
 (2) In this Article-
 (a) The term "interest" includes interest on bonds, securities, notes, deben-
 tures or on any other form of indebtedness;
 (b) The term "royalty" means any royalty or other amount paid as con-
 sideration for the use of, or for the privilege of using, any copyright,
 patent, design, secret process or formula, trade mark or other like pro-
 perty, but does not include any royalty or other amount paid in respect
 of the operation of a mine or quarry or of any other extraction of natural
 resources.
 (3) Where any interest or royalty exceeds a fair and reasonable consideration
in respect of the indebtedness or rights for which it is paid, the exemption
provided by the present article shall apply only to so much 6f the interest or
royalty as represents such fair and reasonable consideration.
 (4) Any capital sum derived from sources within one of the territories from
the sale of patent rights by a resident of the other territory, who does not carry
on a trade or business in the first-mentioned territory through a permanent
establishment situated therein, shall be exempt from tax in that first-mentioned
territory.