Norway - Grenada Tax Treaty

AGREEMENT BETWEEN GRENADA AND THE KINGDOM OF NORWAY

CONCERNING THE EXCHANGE OF INFORMATION RELATING TO TAX MATTERS

The Government of Grenada and the Government of the Kingdom of Norway, desiring to conclude an Agreement concerning information on tax matters, have agreed as follows:

Article 1 Object And scope of the agreement The Competent Authorities Of the Contracting Parties Shall Provide Assistance through exchange of information that is foreseeably relevant to the administration and enforcement of the domestic laws of the Contracting Parties Concerning Taxes Covered By this Agreement. Such Information Shall Include Information That is foreseeably relevant to the determination, assessment and collection of such taxes,the recovery and enforcement of tax Claims, or the investigation or prosecution of tax matters.Informations Shall Be exchanged In accordance with the provisions of this Agreement And Shall Be Treated As Confidential in the manner provided in Article 8. The Rights And Safeguards secured to persons by the laws or practice of the requested administrative Party Remain Applicable To the extent that they do not unduly prevent or delay effective exchange of information.

Article 2 Jurisdiction Party Is not obligated to provide information which is neither held A Requested or control of persons who are within its territory by its authorities nor in the possession jurisdiction.

Article 3 Taxes Covered The Taxes Which are subject of this Agreement Are Taxes Of every kind and description imposed by the Contracting Parties at the date of signature of the Agreement.

This Agreement Shall Also Apply To any identical taxes imposed after the date of signature of the Agreement In addition to or in place of the existing taxes. This Agreement Shall Also apply to any substantially similar taxes imposed after the date of signature of the Agreement in addition to or in place of the existing taxes if the competent authorities of the Contracting the taxes covered maybe expended or modified by mutual Parties agree.Furthermore, of the Contracting Parties in the form of an exchange of letters.The Competent agreement authorities of the Contracting Parties shall motif each others of any substantial changes to the covered by the Agreement, taxation and related information gathering measures Article 4 Definitions

1.For the purposes of this Agreement, un1 less otherwise defined: a) the term "ContractingParty" means Norway or Grenadaasthe context requires; b) the term "Grenada"means the country of Grenada;, c) theterm "Norway"means the Kingdomof Norway,and includes the land territory and internal waters,the territorial sea and the area beyond the territorial seawear the Kingdomof Norway,according to Norwegian legislation and in with international law, may exercise her rights with respect to the accordance seabed and subsoil and their natural resources; the term does not comprise ("biland"); Svalbard,JanMayenandtheNorwegiandependencies d) the term "competent authority"means: (i) in the case of Grenada, the Minister Of Finance Or his authorised representative; (ii) in Norway,theMinisterof Finance Or the Minister'sauthorised representative; e) the term "person"includes an individual,a company and any other body of persons; f) theterm'ocompany" means anybody corporate or any entity that is treated as a body corporate for tax purposes; g) the term "publicly traded company"means any company whose principal provided its listed shares class of shares is listed on a recognised stock exchange can be readily purchased or sold by the public. Shares Can Be purchased or sold "by the public" if the purchase or sale of shares is not implicitly or explicitly restricted to a limited group of investors; h) the term "principal class of shares"means the class or classes of shares representing a majority the voting power and value of the company; i) the term "recognised stock exchange"means any stock exchange agreed upon by the competent authorities of the Contracting Parties; j) the term "collective investment fund or scheme"means any pooled investment vehicle,irrespective of legal form. Theterm "public collective investment fund or scheme"means any collective investment fund or scheme provided the units, shares or other interest in the fund or scheme can be readily purchased, Sold or redeemed by the public. Units, shares or other interests in the fund or scheme Can be readily purchased, Sold or redeemed "by the public" if the purchase, sale or redemption is not implicitly or explicitly restricted to i limited group of investors; k) the term "tax" means any tax to which the Agreement applies; l) the term "applicant Party"means the Contracting Party requesting information; Party"means the Contracting Party requested m) the term "requested to provide information:

or gathering measures" means laws and administrative n) the term of information judicial procedures that enable a Contracting Party to obtain and provide the requested information; o) the term "information"means any fact, statement recording any form whatever; p) the term "criminal tax matters"means tax matters involving intentional conduct which is liable to prosecution under the criminal law of the applicant party; as such under q) the term "criminal laws" means all criminal laws designated domestic law irrespective of whether contained in the tax laws, the criminal Code or other statutes. 2. As regards the application of this Agreement At any time by a Contracting Party, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at That time under the law of that Purty, any meaning under the applicable tax laws of thatParty prevailing over meaning given to the term under other laws of that Party.

Article 5 Exchange Of Information Upon Request Party Shall Provide Upon Request Information For The competent authority of the requested without regard to the purposes referred to in Article 1. Such Information Shall Be exchanged would constitute a crime under the laws of the whether the conduct being investigated Party. Party If Such conduct occurred in the requested requested Party is not of the competent authority of the requested If the information in the possession is sufficient to enable it to comply with the request for information,that Party shall use all to provide the applicant Paris with the information relevant information gathering measures Party may not need such information for its own that the requested, notwithstanding tax purposes.

by the competent authority of an applicantParty,the competent 3. If specifically requested Party Shall Provide Information Under This Article, to the extent authority of the requested allowable under its domestic laws,in the form of depositions of witnesses unauthenticated copies of original records. Each Contracting Party shall ensure that its competent authorities for the purpose specified in Article 1 of the Agreement, have the authority to obtain and provide upon request: a) information held by banks, other financial institutions, and persons acting in an agency or fiduciary capacity including nominees and trustees; partnerships, trusts, b) information regarding the ownership of companies, foundations,"Anstalten"and other persons, including, within the constraints of Article 2, ownership information on all such persons in an ownership chain; in and in the the case of trusts, information on settlors, trustees and beneficiaries; case of foundations, information on founders, members of the foundation Further, this Agreement Does Not create an obligation council and beneficiaries. on the Contracting Parties to obtain provide ownership information with respect to publicly traded companies or public collective investment funds schemes unless such information can be obtained without giving rise to disproportionate difficulties.

The competent authority of the applicant Party Shall Provide The following information to Party When Making A request for information under the competent authority of the requested relevance of the information to the request: the Agreement to demonstrate the foreseeable a) the identity of the person under examination or investigation; b) a statement of the information sought including its nature and the form in which the applicant Party wishes to receive the information from the requested Party; c) the tax purpose for which the information is sought; is held in the requested d) grounds for believing that the information requested Party Or is in the possession or control of a person within the jurisdiction of the Purty; requested e) to the extent known, the name and address of any person believed to be in possession of the requested information; that the request is in conformity with the law and administrative f) a statement practices of the applicant Party, that if the requested information was within the jurisdiction of the applicant Party then the competent authority of the applicant Party Would be able to obtain the information under the laws of the applicant practice and that it is in Party in the normal course of administrative conformity with this Agreement; g) a statement that the applicantPartyhaspursuedall means available in its own territory to obtain the information,except those that would give rise to difficulties. disproportionate information as Party Shall Forward The requested 6. The Competent Authority Of the requested the competent promptly as possible the applicantParty.To ensure a prompt response, Partyshall: authority of the requested a) Confirm Receipt Of a request in writing to the competent authority of the applicantPartyandshallnotifu the competent authority of the applicant Party deficiencies in the request,if any,within 60 days of the receipt of the request. Party Has Been Unable To obtain b) If the competent authority of the requested and provide the information within 90 days of receipt of the request, including if in furnishing the information or it refuses to furnish the obstacles it encounters information, it shall immediately inform the applicant Party, explaining the reason for its ability. the nature of the obstacles or the reasons for its refusal.

Article 6 Tax ExaminationsAbroad of the competent authority of the other l. A ContractingPartymay allow representatives Party To interview individuals ContractingPartyto enter the territory of the first-mentioned The and examine records with the written consent of the persons concerned. Party Shall Notify the competent authority of the competent authority of the second-mentioned Party Of the time and place of the meeting with the individual concerned. first-mentioned 2. At The request of the competent authority of oneContractingParty,the of the competent authority of the otherContractingPartymay allow representatives Party To be present at the appropriate part of a tax competent authority of the first-mentioned Party. examination in the second-mentioned If the request referred to in paragraph 2 is acceded to, the competent authority of the Contracting Party conducting the examination shall, as soon as possible, notify the competent the authority or authority of the other Party about the time and place of the examination, to carry out the examination and procedures and conditions required by official designated Party For the conduct of the examination.All decisions with respect to the the first-mentioned conduct of the tax examinations shall be made by the Party Conducting The examination.

Article 7 Possibility Of Declining A Request

1.The requested Party Shall Not be required to obtain or provide information that the applicant or Party Would not be able to obtain merits own laws for purposes of the administration Party may decline of its own tax laws. The content authority the requested enforcement to assist where the request is not made in conformity with this Agreement.

2.The provisions of this Agreement Shall Not impose on a Contracting Party the obligation to supply information which would disclose any trade, business, industrial, commercial or professional secretor trade process.Notwithstanding the foregoing, information on the type referred to in Article 5, paragraph 4shall not treated such a secretor trade process merely because it meets the criteria in that paragraph.

The Provisions Of this Agreement Shall Not impose on a ContractingPartythe obligation to between obtain or provide information,which would reveal confidential communications client and an attorney,solicitor or other admitted legal representative wheresuch communications are: (a) produced for the purposes of seeking or providing legal advice (b) produced for the pu{poses of using existing or contemplated legal proceedings. The requested Party may decline a request for information if the disclosure of the information would be contrary to public policy (order public).

A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed. The requested Party may decline a request for information if the information is requested by the applicant Party to administer or enforce a provision of the tax law of the applicant ParW, or any requirement connected there with, which discriminates against national the requested Party as compared with a national of the applicant Party in the same circumstances.

Article 8 Confidentiality Any information received by a Contractor Party Under This Agreement Shall Be Treated As confidential and may be disclosed only to persons or authorities(including courts and administrative bodies)in the jurisdiction of the Contracting Party concerned with the assessment or collection of, the enforcement or prosecution in respect of or the determination of appeals in relation to, the taxes covered by this Agreement.Such Persons Or authorities shall us such information only for such purposes.They May disclose the information in public court proceedings or in judicial decisions.The information may not be disclosed to any other person or entity or authority or any other jurisdiction without the express written consent of the competent authority of the requested Party.

Article 9 Costs Incidence Of Costs incurred in providing assistance shall be agreed by the ContractingParties.

Article 10 Mutual agreement procedure Where difficulties arise between the Contracting Contracting Parties regarding the implementation or interpretation of this Agreement, the respective competent authorities shall endeavour to resolve the matter by mutual agreement.

In addition to the agreements referred to in paragraph1,the competent authorities of the ContractingPartiesmay mutually agree on the procedures to be used under Article 5 and6. The competent authorities of the Contracting Parties may communicate with each other directly for purposes of reaching agreement under this Article.

Article 11 Entry into Force Each Of the ContractingPartiesshallnotify the other in writing of the completion of the procedures required by its law for the entry into force of this Agreement. 2.The Agreement Shall Enter Into force on the thirtieth after the receipt of the later of these notifications and shall thereupon have effect for criminal tax matters,on that date; for all other matters covered in Article 1, for taxable periods beginning on or after the first day of January Of the year next following the date on which the Agreement Enters Into force, or where there is no taxable period, for all charges to tax arising on or after that date.

Article 12 Termination L This Agreement Shall Main in force until terminated by a Contracting Party. Either Contracting Party may terminate the Agreement By giving written notice of termination to the otherContractingParty.In such case, the Agreement Shall Cease To have effect on the first day of the month following the end of the period of six months after the date of receipt of notice of termination by the other Contracting Party.

In the event of termination, both Contracting Parties shall remain bound by & provisions of Article 8 with respect to any information obtained under the Agreement.