Thisconventionwaspublishedintheofficialgazetteonthe20 ofOctober2003andits provisionsshallhaveeffectinrespectoftaxesonincomeobtainedandamountpaid,creditedto anaccount,putatthedisposaloraccountedasanexpense,onorafterthefirstdayofJanuary 2004 CONVENTIONBETWEENTHEREPUBLICOFCHILEANDTHEKINGDOMOFNORWAYFORTHE AVOIDANCEOFDOUBLETAXATIONANDTHEPREVENTIONOFFISCALEVASIONWITH RESPECTTOTAXESONINCOMEANDONCAPITAL

th

The Government of the Republic of Chile and the Government of the Kingdom of Norway, desiring to conclude a Convention for the avoidance of double taxation and the prevention of fiscal evasionwithrespecttotaxesonincomeandoncapital Haveagreedasfollows:

CHAPTERI SCOPEOFTHECONVENTION

Article1
PERSONSCOVERED This Convention shall apply to persons who are residents of one or both of the Contracting States.

Article2
TAXESCOVERED 1. This Convention shall apply to taxes on income and on capital imposed on behalf of a Contracting State or of its political subdivisions or localauthorities,irrespectiveofthemannerinwhich theyarelevied. 2. Thereshallberegardedastaxesonincomeandoncapitalalltaxesimposedontotalincome,on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movableorimmovableproperty,taxesonthetotalamountofwagesorsalariespaidbyenterprises,as wellastaxesoncapitalappreciation. 3. TheexistingtaxestowhichtheConventionshallapplyareinparticular: (a) inChile: thetaxesimposedundertheIncomeTaxAct,LeysobreImpuestoalaRenta (hereinafterreferredtoasChileantax)and inNorway: (i) (ii) (iii) (iv) (v) (vi) thenationaltaxonincome(inntektsskatttilstaten) thecountymunicipaltaxonincome(inntektsskatttilfylkeskommunen) themunicipaltaxonincome(inntektsskatttilkommunen) thenationaltaxoncapital(formuesskatttilstaten) themunicipaltaxoncapital(formuesskatttilkommunen)and thenationaltaxonremunerationtononresidentartistesetc(skatttilstatenp honorartilutenlandskeartisterm.v.) (hereinafterreferredtoas"Norwegiantax") 4. The Convention shall apply also to any identical or substantially similar taxes and to taxes on capitalwhichareimposedafterthedateofsignatureoftheConventioninadditionto,orinplaceof,the existingtaxes.ThecompetentauthoritiesoftheContractingStatesshall,attheendofeachyear,notify eachotherofanysignificantchangeswhichhavebeenmadeintheirrespectivetaxationlaws.

(b)

CHAPTERII DEFINITIONS

Article3
GENERALDEFINITIONS 1. ForthepurposesofthisConvention,unlessthecontextotherwiserequires: (a) (b) (c) (d) (e) (f) thetermChilemeanstheRepublicofChile the term Norway means the Kingdom of Norway, (but for the purpose of this Convention)excludingSvalbard,JanMayenandtheNorwegiandependencies(biland) the terms "aContracting State" and "the other Contracting State"mean,asthecontext requires,ChileorNorway theterm"person"includesanindividual,acompanyandanyotherbodyofpersons theterm"company"meansanybodycorporateoranyentitywhichistreatedasabody corporatefortaxpurposes the terms "enterprise of a Contracting State" and "enterprise of the other Contracting State" mean respectively an enterprise carried on by a resident of a Contracting State andanenterprisecarriedonbyaresidentoftheotherContractingState the term "international traffic" means any transport by a ship or aircraft except when suchtransportissolelybetweenplacesintheotherContractingState theterm"competentauthority"means: (i) (ii) (i) in the case of Chile, the Minister of Finance or the Ministers authorised representative,and inthecaseofNorway,theMinisterofFinanceortheMinistersrepresentative

(g) (h)

theterm"national"means: (i) (ii) anyindividualpossessingthenationalityofaContractingStateor any legal personorassociationconstitutedinaccordancewiththelawsinforce inaContractingState.

2. As regards the application of the Convention at any time by a Contracting State, any term not defined therein shall, unless the context otherwise requires, have the meaning that it has at that time underthelawofthatStateforthepurposesofthetaxestowhichtheConventionapplies,anymeaning undertheapplicabletaxlawsofthatStateprevailingoverameaninggiventothetermunderotherlaws ofthatState. 3

Article4
RESIDENT 1. For the purposes of this Convention, the term "resident of a Contracting State" means any person who, under the laws of that State, is liable to tax therein by reason of the person's domicile, residence,placeofmanagement,placeofincorporationoranyothercriterionofasimilarnatureandalso includesthatStateandanypoliticalsubdivisionorlocalauthoritythereof.Thisterm,however,doesnot includeanypersonwhoisliabletotaxinthatStateinrespectonlyofincomefromsourcesinthatState, orofcapitalsituatedtherein. 2. Wherebyreasonoftheprovisionsofparagraph1anindividualisaresidentofbothContracting States,thentheindividual'sstatusshallbedeterminedasfollows: (a) theindividualshallbedeemedtobearesidentonlyoftheStateinwhichtheindividual has a permanent home available if the individual has a permanent home available in bothStates,theindividualshallbedeemedtobearesidentonlyoftheStatewithwhich theindividual'spersonalandeconomicrelationsarecloser(centreofvitalinterests) if the Stateinwhichtheindividualscentreofvitalinterestscannotbedetermined,orif there is not a permanent home availabletotheindividualineitherState,theindividual shallbedeemedtobearesidentonlyoftheStateinwhichtheindividualhasanhabitual abode iftheindividualhasanhabitualabodeinbothStatesorinneitherofthem,theindividual shallbedeemedtobearesidentonlyoftheStatesofwhichtheindividualisanational if the individual is a national of both States or of neither of them, the competent authorities of the Contracting States shall settle the question by mutual agreement procedure.

(b)

(c) (d)

3. Wherebyreasonoftheprovisionsofparagraph1apersonotherthananindividualisaresident ofbothContractingStates,thecompetentauthoritiesoftheContractingStatesshallendeavourtosettle the question by mutual agreement procedure. In the absence of a mutual agreement, the person shall notbeentitledtoclaimanyrelieforexemptionfromtaxprovidedbytheConvention.

Article5
PERMANENTESTABLISHMENT 1. ForthepurposesofthisConvention,theterm"permanentestablishment"meansafixedplaceof businessthroughwhichthebusinessofanenterpriseiswhollyorpartlycarriedon. 2. Theterm"permanentestablishment"includesespecially: (a) (b) (c) (d) (e) (f) 3. aplaceofmanagement abranch anoffice afactory aworkshopand amine,anoilorgaswell,aquarryoranyotherplaceoforrelatingtotheexplorationfor ortheexploitationofnaturalresources.

Thetermpermanentestablishmentshallalsoinclude: (a) a building site or construction or installation project and the supervisory activities in connection therewith, but only if such building site, construction or activities last more thansixmonths,and the furnishing of services, including consultancy services, by an enterprise through employees or other individuals engaged by the enterprise for such purpose, but only where such activities continue within the country for a period or periods aggregating morethansixmonthswithinanytwelvemonthperiod.

(b)

For the purposes of computing the time limits in this paragraph, activities carried on by an enterpriseassociatedwithanotherenterprisewithinthemeaningofArticle9ofthisConventionshallbe aggregatedwiththeperiodduringwhichactivitiesarecarriedonbytheenterpriseiftheactivitiesofthe associatedenterprisesaresubstantiallythesame. 4. Notwithstanding the preceding provisions of this Article, the term "permanent establishment" shallbedeemednottoinclude: (a) (b) (c) (d) the use of facilities solely for the purpose of storage, display or delivery of goods or merchandisebelongingtotheenterprise the maintenance of a stock of goods or merchandise belonging to theenterprisesolely forthepurposeofstorage,displayordelivery the maintenance of a stock of goods or merchandise belonging to theenterprisesolely forthepurposeofprocessingbyanotherenterprise themaintenanceofafixedplaceofbusinesssolelyforthepurposeofpurchasinggoods ormerchandiseorofcollectinginformation,fortheenterprise 5

(e)

the maintenance of a fixed place of business solely for the purpose of advertising, supplyinginformationorcarryingoutscientificresearchfortheenterpriseandanyother similaractivityifitisofapreparatoryorauxiliarycharacter.

5. Notwithstanding the provisions of paragraphs1 and2ofthisArticlewhereaperson(otherthan anagentofanindependentstatustowhomparagraph7ofthisArticleapplies)isactingonbehalfofan enterpriseandhasandhabituallyexercisesinaContractingStateanauthoritytoconcludecontractson behalfoftheenterprise,thatenterpriseshallbedeemedtohaveapermanentestablishmentinthatState inrespectofanyactivitieswhichthatpersonundertakesfortheenterprise,unlesstheactivitiesofsuch person are limited to those mentioned in paragraph4 which, if exercised through a fixed place of business,wouldnotmakethisfixedplaceofbusinessapermanentestablishmentundertheprovisionsof thatparagraph. 6. Notwithstanding the preceding provisions of this Article, an insurance company resident of a Contracting State shall, except in the case of reinsurance, be deemed to have a permanent establishmentintheotherContractingStateifitcollectspremiumsintheterritoryofthatotherStateorif it insures risks situated therein through a representative other than an agent of independent status to whomparagraph7ofthisArticleapplies. 7. An enterprise shall not be deemed to have a permanent establishment in a Contracting State merely because it carries on business in that Statethroughabroker,generalcommissionagentorany other agent of an independent status, provided that such persons are acting in the ordinary course of theirbusiness,andthattheconditionsthataremadeorimposedintheircommercialorfinancialrelations withsuchenterprisesdonotdifferfromthosewhichwouldbegenerallymadebyindependentagents. 8. ThefactthatacompanywhichisaresidentofaContractingStatecontrolsoriscontrolledbya company which is a resident of the other Contracting State, or which carries on business in that other State (whether through a permanent establishment or otherwise), shall not of itself constitute either companyapermanentestablishmentoftheother.

CHAPTERIII TAXATIONOFINCOME

Article6
INCOMEFROMIMMOVABLEPROPERTY 1. IncomederivedbyaresidentofaContractingStatefromimmovableproperty(includingincome fromagricultureorforestry)situatedintheotherContractingStatemaybetaxedinthatotherState. 2. For the purposes of this Convention, the term "immovable property" shall have the meaning whichithasunderthelawoftheContractingStateinwhichthepropertyinquestionissituated.Theterm shallinanycasecomprisepropertyaccessorytoimmovablepropertyincludinglivestockandequipment usedinagricultureandforestry,rightstowhichtheprovisionsofgenerallawrespectinglandedproperty apply, usufruct of immovable property andrightstovariableorfixedpaymentsasconsiderationforthe workingof,ortherighttowork,mineraldeposits,sourcesandothernaturalresources.Shipsandaircraft shallnotberegardedasimmovableproperty. 3. Theprovisionsofparagraph1shallapplytoincomederivedfromthedirectuse,letting,orusein anyotherformofimmovableproperty. 4. Theprovisionsofparagraphs1and3shallalsoapplytotheincomefromimmovablepropertyof anenterpriseandtoincomefromimmovablepropertyusedfortheperformanceofindependentpersonal services.

Article7
BUSINESSPROFITS 1. TheprofitsofanenterpriseofaContractingStateshallbetaxableonlyinthatStateunlessthe enterprisecarriesonbusinessintheotherContractingStatethroughapermanentestablishmentsituated therein.Iftheenterprisecarriesonorhascarriedonbusinessasaforesaid,theprofitsoftheenterprise may be taxed in the other State but only so much of them as is attributable to that permanent establishment. 2. Subject to the provisions of paragraph3, where an enterprise of a ContractingStatecarrieson businessintheotherContractingStatethroughapermanentestablishmentsituatedtherein,thereshallin each Contracting State be attributed to that permanent establishment the profits which it might be expected to make if it were adistinctandseparateenterpriseengagedinthesameorsimilaractivities underthesameorsimilarconditionsanddealingwhollyindependentlywiththeenterpriseofwhichitisa permanentestablishmentandwithallotherpersons. 3. In determining the profits of a permanent establishment, there shall be allowed as deductions expenses which are incurred for the purposes of the permanent establishment including executive and generaladministrativeexpensessoincurred,whetherintheStateinwhichthepermanentestablishment issituatedorelsewhere. 4. InsofarasithasbeencustomaryinaContractingStatetodeterminetheprofitstobeattributed toapermanentestablishmentonthebasisofanapportionmentofthetotalprofitsoftheenterprisetoits variousparts,nothinginparagraph2shallprecludethatContractingStatefromdeterminingtheprofitsto be taxed by such an apportionment as maybecustomarythemethodofapportionmentadoptedshall, however,besuchthattheresultshallbeinaccordancewiththeprinciplescontainedinthisArticle. 5. No profits shall be attributed to a permanent establishment by reasonofthemerepurchaseby thatpermanentestablishmentofgoodsormerchandisefortheenterprise. 6. For the purposes of the preceding paragraphs, the profits to be attributed to the permanent establishmentshallbedeterminedbythesamemethodyearbyyearunlessthereisgoodandsufficient reasontothecontrary. 7. Where profits include items of income which are dealt with separately in other Articles of this Convention,thentheprovisionsofthoseArticlesshallnotbeaffectedbytheprovisionsofthisArticle.

Article8
SHIPPINGANDAIRTRANSPORT 1. Profits of an enterprise of a Contracting State from the operation of ships or aircraft in internationaltrafficshallbetaxableonlyinthatState. 2. ForthepurposesofthisArticle: (a) thetermprofitsincludes: (i) gross revenues derived directly from the operation of ships or aircraft in 8

internationaltraffic,and (ii) (b) interestovertheamountsderiveddirectlyfromtheoperationofshipsoraircraft ininternationaltraffic,onlyifsuchinterestisincidentaltotheoperation.

the term operation of ships and aircraft by an enterprise, also includes the charter or rentalonabareboatbasisofshipsandaircraftifthatcharterorrentalisincidentaltothe operationbytheenterpriseofshipsoraircraftininternationaltraffic.

3. ProfitsofanenterpriseofaContractingStatefromtheuse,maintenanceorrentalofcontainers used for the transport of goods or merchandise in international traffic shall be taxable only in that ContractingState. 4. The provisions of paragraph1 shall also apply to profitsfromtheparticipationinapool,ajoint businessoraninternationaloperatingagency.

Article9
ASSOCIATEDENTERPRISES 1. Where (a) (b) anenterpriseofaContractingStateparticipatesdirectlyorindirectlyinthemanagement, controlorcapitalofanenterpriseoftheotherContractingState,or thesamepersonsparticipatedirectlyorindirectlyinthemanagement,controlorcapital ofanenterpriseofaContractingStateandanenterpriseoftheotherContractingState,

and in either case conditions are made or imposed between the two enterprises in their commercial or financial relations which differ fromthosewhichwouldbemadebetweenindependententerprises,then anyprofitswhichwould,butforthoseconditions,haveaccruedtooneoftheenterprises,but,byreason of those conditions, has not so accrued, may be included in the profits of that enterprise and taxed accordingly. 2. Where a Contracting State includes in the profits of an enterprise of that State and taxes accordinglyprofitsonwhichanenterpriseoftheotherContractingStatehasbeenchargedtotaxinthat other State and the profits so included are profits which would have accrued to the enterprise of the firstmentioned State if the conditions made between the two enterprises had been those which would have been made between independent enterprises, then that other State, shall, if it agrees, make an appropriate adjustment to the amount of tax charged therein on those profits. In determining such adjustment, due regard shall be had to the other provisions of this Convention and the competent authoritiesoftheContractingStatesshallifnecessaryconsulteachother.

10

Article10
DIVIDENDS 1. DividendspaidbyacompanythatisaresidentofaContractingStatetoaresidentoftheother ContractingStatemaybetaxedinthatotherState. 2. Such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State. However, if the beneficial owner of the dividendsisaresidentoftheotherContractingState, thetaxsochargedshallnotexceed: (a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company that controlsdirectlyorindirectlyatleast25percentofthevotingpowerinthecompanypaying thedividends,and 15percentofthegrossamountofthedividends,inallothercases.

(b)

Theprovisionsofthisparagraphshallnotaffectthetaxationofthecompanyinrespectoftheprofits outofwhichthedividendsarepaid. 3. Theterm"dividends"asusedinthisArticlemeansincomefromsharesorotherrights,notbeing debtclaims,participatinginprofits,aswellasincomefromotherrightswhichissubjectedtothesame taxation treatment as income from shares by the laws of the State of which the company making the distributionisaresident. 4. Theprovisionsofparagraphs1and2ofthisArticleshallnotapplyifthebeneficialownerofthe dividends,beingaresidentofaContractingState,carriesonbusinessintheotherContractingStateof which the company paying the dividends is a resident, through a permanent establishment situated therein,orperformsinthatotherStateindependentpersonalservicesfromafixedbasesituatedtherein, andtheholdinginrespectofwhichthedividendsarepaidiseffectivelyconnectedwithsuchpermanent establishmentorfixedbase.InsuchcasetheprovisionsofArticle7orArticle14,asthecasemaybe, shallapply. 5. Where a company that is a resident of a Contracting State derives profits or income from the otherContractingState,thatotherStatemaynotimposeanytaxonthedividendspaidbythecompany, except insofar as such dividends are paid to a resident of that other State or insofar as the holding in respect of which the dividends are paid is effectively connected with a permanent establishment or a fixed base situated in that other State, nor subject the company's undistributed profits to a tax on undistributed profits, even if the dividends paid or the undistributed profits consist wholly or partly of profitsorincomearisinginsuchotherState.

Article11
INTEREST 1. InterestarisinginaContractingStateandpaidtoaresidentoftheotherContractingStatemay betaxedinthatotherState. 2. However, such interest may also be taxed in the Contracting State in which it arises and according to the laws of that State, but if the beneficial owner of the interest is a resident of the other 11

ContractingState,thetaxsochargedshallnotexceed15percentofthegrossamountoftheinterest. 3. Theterm"interest"asusedinthisArticlemeansincomefromdebtclaimsofeverykind,whether or not secured by mortgage, and in particular, income from government securities and income from bonds or debentures, as well as income which is subjected to the same taxation treatment as income frommoneylentbythelawsoftheStateinwhichtheincomearises.Theterminterestshallnotinclude incomedealtwithinArticle10. 4. Theprovisionsofparagraphs1and2ofthisArticleshallnotapplyifthebeneficialownerofthe interest, being a resident of a Contracting State, carries on business in the other Contracting State in which the interest arises through a permanent establishment situated therein, or performs in that other Stateindependentpersonalservicesfromafixedbasesituatedtherein,andthedebtclaiminrespectof which the interest is paid is effectively connected with such permanent establishment or fixed base. In suchcasetheprovisionsofArticle7orArticle14ofthisConvention,asthecasemaybe,shallapply. 5. Interest shall be deemed to arise in a Contracting State when the payer is a resident of that State.Where,however,thepersonpayingtheinterest,whetheraresidentofaContractingStateornot, has in a Contracting State a permanent establishment or a fixed base in connection with which the indebtedness on which the interest is paid was incurred, and such interest is bornebysuchpermanent establishment or fixed base, then such interest shall be deemed to arise in the State in which the permanentestablishmentorfixedbaseissituated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or betweenbothofthemandsomeotherperson,theamountoftheinterest,havingregardtothedebtclaim for which it is paid, exceeds the amount that would have been agreed upon by the payer and the beneficialownerintheabsenceofsuchrelationship,theprovisionsofthisArticleshallapplyonlytothe lastmentionedamount.Insuchcase,theexcesspartofthepaymentsshallremaintaxableaccordingto thelawsofeachContractingState,dueregardbeinghadtotheotherprovisionsofthisConvention. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposesofanypersonconcernedwiththecreationorassignmentofthedebtclaiminrespectofwhich theinterestispaidtotakeadvantageofthisArticlebymeansofthatcreationorassignment.

12

Article12
ROYALTIES

1. RoyaltiesarisinginaContractingStateandpaidtoaresidentoftheotherContractingStatemay betaxedinthatotherState. 2. However, such royalties may also be taxed in the Contracting State in which they arise and according to the laws of that State, but ifthebeneficialowneroftheroyaltiesisaresidentoftheother ContractingState,thetaxsochargedshallnotexceed: (a) (b) 5 per cent of the gross amount of royalties for the use, or the right to use industrial, commercialorscientificequipment 15percentofthegrossamountoftheroyalties,inallothercases.

3. The term "royalties" as used in this Article means payments of any kind received as a consideration for the use of, or the right to use, any copyright of literary, artistic or scientific work, includingcinematographicfilmsorfilms,tapesandothermeansofimageorsoundreproduction,patent, trademark,designormodel,plan,secretformulaorprocessorotherintangibleproperty,orfortheuse of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial,commercialorscientificexperience. 4. Theprovisionsofparagraphs1and2ofthisArticleshallnotapplyifthebeneficialownerofthe royalties, being a resident of a Contracting State, carries on business in the other Contracting State in which the royalties arise, through a permanent establishment situated therein,orperformsinthatother State independent personal services from a fixed base situated therein, and the right or property in respect of which the royalties are paid is effectively connected with such permanent establishment or fixedbase.InsuchcasetheprovisionsofArticle7orArticle14ofthisConvention,asthecasemaybe, shallapply. 5. Royalties shall be deemed to arise in a Contracting State when the payer is a resident of that State.Where,however,thepersonpayingtheroyalties,whetheraresidentofaContractingStateornot, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the royalties was incurred, and such royalties are borne by such permanent establishment or fixed base, then such royalties shall be deemed to arise in the State in which the permanentestablishmentorfixedbaseissituated. 6. Where, by reason of a special relationship between the payer and the beneficial owner or betweenbothofthemandsomeotherperson,theamountoftheroyaltieshavingregardtotheuse,right or information for which they are paid exceeds the amount that would have been agreed upon by the payer and the beneficial owner in the absence of such relationship, the provisions of this Article shall apply only to the lastmentioned amount. In such case, the excess part of the payments shall remain taxableaccordingtothelawsofeachContractingState,dueregardbeinghadtotheotherprovisionsof thisConvention. 7. The provisions of this Article shall not apply if it was the main purpose or one of the main purposes of any person concerned with the creation orassignmentoftherightsinrespecttowhichthe royaltiesarepaidtotakeadvantageofthisArticlebymeansofthatcreationorassignment.

13

14

Article13
CAPITALGAINS 1. Gains derived by a resident of a Contracting State from the alienation of immovable property situatedintheotherContractingStateshallbetaxableonlyinthatotherState. 2. Gains from the alienation of movable property forming part of the business property of a permanentestablishmentthatanenterpriseofaContractingStatehasintheotherContractingStateor ofmovablepropertypertainingtoafixedbaseavailabletoaresidentofaContractingStateintheother Contracting State for the purpose of performing independent personal services, including such gains fromthealienationofsuchapermanentestablishment(aloneorwiththewholeenterprise)orofsucha fixedbase,maybetaxedinthatotherState. 3. Gainsfromthealienationofships,aircraftorcontainersoperatedininternationaltrafficorfrom movable property pertaining to the operation of such ships or aircraft shall be taxable only in the ContractingStateofwhichthealienatorisaresident. 4. Gains derived by a resident of a Contracting State from the alienation of instruments or other rights representing the capital of a company or any other type of financial instruments situated in the otherContractingStatemaybetaxedinthatotherState. 5. Gains from the alienation of any property other than that referred to in the above mentioned paragraphs,shallbetaxableonlyintheContractingStateofwhichthealienatorisaresident.

15

Article14
INDEPENDENTPERSONALSERVICES 1. IncomederivedbyanindividualwhoisaresidentofaContractingStateinrespectofprofessional services or other activitiesofanindependentcharactershall betaxableonlyinthatContractingState. However,suchincomemayalsobetaxedintheotherContractingState: (a) if he has a fixed base regularly available in the other Contracting State for purpose of performing the activities in that case, only so much of the income as is attributable to thatfixedbasemaybetaxedinthatotherState if he is present in the other Contracting State for a period or periods amounting to or exceedingintheaggregate183daysinany12monthperiodinthatcase,onlysomuch of the income as is derived from the activities performed in that other State may be taxedinthatState.

(b)

2. The term "professional services" includes especially independent scientific, literary, artistic, educationalorteachingactivitiesaswellastheindependentactivitiesofphysicians,lawyers,engineers, architects,dentistsandaccountants.

16

Article15
DEPENDENTPERSONALSERVICES 1. Subject to the provisions of Articles16, 18 and 19, salaries, wages and other remuneration derived by a resident of a Contracting State in respect of an employment shall be taxable only in that State unless the employment is exercised in the other Contracting State. If the employment is so exercised,suchremunerationasisderivedtherefrommaybetaxedinthatotherState. 2. Notwithstanding the provisions of paragraph1, remuneration derived by a resident of a ContractingStateinrespectofanemploymentexercisedintheotherContractingStateshallbetaxable onlyinthefirstmentionedStateif: (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate183daysinanytwelvemonthperiodcommencingorendinginthefiscalyear concerned,and theremunerationispaidby,oronbehalfof,apersonwhoisnotaresidentoftheother State,and the remuneration is not borne by a permanent establishment or a fixed base that the personhasintheotherState.

(b) (c)

3. NotwithstandingtheprecedingprovisionsofthisArticle,remunerationderivedbyaresidentofa Contracting State in respect of an employment exercised aboard a ship or aircraft operated in internationaltrafficshallbetaxableonlyinthatState.

17

Article16
DIRECTORS'FEES Directors' fees and other similar payments derived by a resident of a Contracting State in that resident's capacity as a member of the board of directors or a similar organ of a company which is a residentoftheotherContractingStatemaybetaxedinthatotherState.

18

Article17
ARTISTESANDSPORTSPERSONS 1. Notwithstanding the provisions of Articles14 and 15, income derived by a resident of a Contracting State as an entertainer, such as a theatre, motion picture, radio or television artiste, or a musician, or as a sportsperson, from that resident's personal activities as such exercised in the other Contracting State, may be taxed in that other State. The income referred to in this paragraph shall include any income derived from any personal activity exercised in the other State related with that personsrenownasanartisteorsportperson. 2. Notwithstanding the provisions of Articles 7, 14 and 15, where income in respect of personal activitiesexercisedbyanentertainerorasportspersoninthatindividual'scapacityassuchaccruesnot to the entertainer or sportsperson personally but to another person, that income may be taxed in the ContractingStateinwhichtheactivitiesoftheentertainerorsportspersonareexercised.

19

Article18
PENSIONS 1. PensionsarisinginaContractingStateandpaidtoaresidentoftheotherContractingStatemaybe taxedinthefirstmentionedState,butthetaxsochargedshallnotexceed15percentofthegrossamountof thepensions. 2. AlimonyandothermaintenancepaymentspaidtoaresidentofaContractingStateshallbetaxable only in that State. However, any alimony or other maintenance payments paid by a resident of one of the ContractingStatetoaresidentoftheotherContractingState,shall,totheextentitisnotallowableasareliefto thepayer,betaxableonlyinthefirstmentionedState.

20

Article19
GOVERNMENTSERVICE 1. (a) Salaries, wages and other remuneration, other than a pension, paid by a Contracting State or a political subdivision or a local authority thereof to an individual in respectof services rendered to that State or subdivision or authority shall be taxable only in that State. However,suchsalaries,wagesandotherremunerationshallbetaxableonlyintheother Contracting State if the services are rendered in that State and the individual is a residentofthatStatewho: (i) (ii) isanationalofthatStateor did not become a resident of that State solely for the purpose of rendering the services.

(b)

2. TheprovisionsofArticles15,16and17shallapplytosalaries,wagesandotherremunerationin respectofservicesrenderedinconnectionwithabusinesscarriedonbyaContractingStateorapolitical subdivisionoralocalauthoritythereof.

21

Article20
STUDENTS Payments which a student, apprentice or business trainee who is, or was immediately before visiting a Contracting State, a resident of the other Contracting State and who is present in the firstmentioned State solely for the purpose of that individual's education or training receives for the purpose of that individual's maintenance, education or training shall not be taxed in that State, if such paymentsarisefromsourcesoutsidethatState.

22

Article21
OTHERINCOME ItemsofincomeofaresidentofaContractingStatenotdealtwithintheforegoingArticlesofthisConvention andarisingintheotherContractingStatemayalsobetaxedinthatotherState.

23

CHAPTERIV TAXATIONOFCAPITAL

Article22
CAPITAL 1. Capital represented by immovable property owned by a resident of a Contracting State and situatedintheotherContractingStatemaybetaxedinthatotherState. 2. Capital represented by movable property forming part of the business property of a permanent establishmentthatanenterpriseofaContractingStatehasintheotherContractingState,orbymovable propertypertainingtoafixedbaseavailabletoaresidentofaContractingStateintheotherContracting Stateforthepurposeofperformingindependentpersonalservices,maybetaxedinthatotherState. 3. CapitalofanenterpriseofaContractingStaterepresentedbyshipsoraircraftoperatedin internationaltraffic,andbymovablepropertypertainingtotheoperationofsuchshipsoraircraft,shallbe taxableonlyinthatContractingState. 4. Capital of an enterprise of aContractingStaterepresentedbycontainersusedforthetransport of goods or merchandise shall be taxable only in that Contracting State, except insofar as those containersareusedfortransportsolelybetweenplaceswithintheotherContractingState. 5. All other elements of capital of a resident of a Contracting State shall be taxable only in that State.

24

CHAPTERV METHODSFORAVOIDANCEOFDOUBLETAXATION

Article23
AVOIDANCEOFDOUBLETAXATION

1.

InthecaseofChile,doubletaxationshallbeavoidedasfollows: (a) residentsinChile,obtainingincomewhichmay,inaccordancewiththeprovisionsofthis Convention be subject to taxation in Norway, may credit the tax so paid against any Chileantaxpayableinrespectofthesameincome,subjecttotheapplicableprovisions ofthelawofChile.ThisparagraphshallalsoapplytoincomereferredtoinArticles6and 11 where, in accordance with any provision of the Convention, income derived or capital owned by a resident of Chile is exempt from tax in Chile, Chile may nevertheless, in calculatingtheamountoftaxonotherincomeorcapital,takeintoaccounttheexempted incomeorcapital.

(b)

2.

InthecaseofNorway,doubletaxationshallbeavoidedasfollows:

Subject to the provisions of the laws of Norway regarding the allowance as a credit against Norwegian tax of tax payable in a territory outside Norway (which shall not affect the general principle hereof), (a) where a resident of Norway derives income or owns elements of capital which, in accordance withtheprovisionsofthisConvention,maybetaxedinChile,Norwayshall allow: (i) (ii) as a deduction from thetaxontheincomeofthatresident,anamountequal to theincometaxpaidinChileonthatincome as a deduction from the tax on the capital of that resident, an amount equal to thecapitaltaxpaidinChileonelementsofcapital

Such deduction ineithercaseshallnot,however,exceedthatpartoftheincometaxor capitaltax,ascomputedbeforethedeductionisgiven,whichisattributable,asthecase maybe,totheincomeorthesameelementsofcapitalwhichmaybetaxedinChile. (b) where in accordance with any provision of the Convention income derived or capital ownedbyaresidentofNorwayisexemptfromtaxinNorway,Norwaymaynevertheless include such income or capital in the tax base, but shall allow as a deduction from the Norwegiantaxonincomeorcapitalthatpartoftheincometaxorcapitaltax,asthecase maybe,whichisattributabletotheincomederivedfromtheotherContractingState,or thecapitalownedinthatotherState.

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CHAPTERVI SPECIALPROVISIONS

Article24
NONDISCRIMINATION 1. Nationals of a Contracting State shall not be subjected in the other Contracting State to any taxation or any requirement connected therewith, which is other ormoreburdensomethanthetaxation and connected requirements to which nationals of that other State in the same circumstances, in particularwithrespecttoresidence,areormaybesubjected. 2. ThetaxationonapermanentestablishmentthatanenterpriseofaContractingStatehasinthe otherContractingStateshallnotbelessfavourablyleviedinthatotherStatethanthetaxationleviedon enterprisesofthatotherStatecarryingonthesameactivities. 3. NothinginthisArticleshallbeconstruedasobligingaContractingStatetogranttoresidentsof the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on accountofcivilstatusorfamilyresponsibilitiesthatitgrantstoitsownresidents. 4. Companies which are residents of a Contracting State, the capital of which is wholly or partly ownedorcontrolled,directlyorindirectly,byoneormoreresidentsoftheotherContractingState,shall notbesubjectedinthefirstmentionedStatetoanytaxationoranyrequirementconnectedtherewiththat is other or more burdensome than the taxation and connected requirements to which other similar companiesofthefirstmentionedStateareormaybesubjected. 5. InthisArticle,theterm"taxation"meanstaxesthatarethesubjectofthisConvention.

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Article25
MUTUALAGREEMENTPROCEDURE 1. Whereaperson considersthattheactionsofoneorbothoftheContractingStatesresultorwill result for that person in taxation not in accordance with the provisions of this Convention, that person may,irrespectiveoftheremediesprovidedbythedomesticlawofthoseStates,presentitscasetothe competent authority of the Contracting State of which that personisaresidentor,ifthatpersonscase comesunderparagraph1ofArticle24,tothatoftheContractingStateofwhichthatpersonisanational. 2. Thecompetentauthorityshallendeavour,iftheobjectionappearstoittobejustifiedandifitis not itself able to arrive atasatisfactorysolution,toresolvethecasebyamutualagreementprocedure withthecompetentauthorityoftheotherContractingState,withaviewtotheavoidanceoftaxationnot inaccordancewiththeConvention. 3. The competent authorities of the Contracting States shall endeavour to resolve by a mutual agreement procedure any difficulties or doubts arising as to the interpretation or application of the Convention. 4. The competent authorities of the Contracting States may communicate witheachotherdirectly forthepurposeofreachinganagreementinthesenseoftheprecedingparagraphs.

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Article26
EXCHANGEOFINFORMATION 1. The competent authorities of the Contracting States shall exchange such information as is necessary for carrying out the provisions of this Convention or of the domestic laws in the Contracting StatesconcerningtaxescoveredbytheConventioninsofarasthetaxationthereunderisnotcontraryto theConvention.TheexchangeofinformationisnotrestrictedbyArticle1.Anyinformationreceivedbya Contracting State shall be treated as secret in the same manner as information obtained under the domestic laws of that State and shall be disclosed only to persons or authorities (including courts and administrative bodies) involved in 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 Convention. Such persons or authorities shall use the information only for such purposes. They may disclose the informationinpubliccourtproceedingsorinjudicialdecisions. 2. In no case shall the provisions of paragraph1 be construed so as to impose on a Contracting Statetheobligation: (a) (b) (c) to carry out administrative measures at variance with the laws and the administrative practiceofthatoroftheotherContractingState tosupplyinformationthatisnotobtainableunderthelawsorinthenormalcourseofthe administrationofthatoroftheotherContractingState tosupplyinformationwhichwoulddiscloseanytrade,business,industrial,commercialor professional secret or trade process, or information, the disclosure of which would be contrarytopublicpolicy(ordrepublic).

3. If information is requested by a Contracting State in accordance with this Article, the other ContractingStateshallendeavourtoobtaintheinformationtowhichtherequestrelatesinthesameway as if its own taxation were involved even though the other State does not, at that time, need such information. If specifically requested by the competent authorityofaContractingState,thecompetent authority of the other Contracting State shall endeavour to provide information under this Article in the form requested, such as depositions of witnesses and copies of unedited original documents(including books, papers, statements, records, accounts or writings), to the same extent such depositions and documentscanbeobtainedunderthelawsandadministrativepracticesofthatotherStatewithrespect toitsowntaxes.

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Article27
MEMBERSOFDIPLOMATICMISSIONSANDCONSULARPOSTS NothinginthisConventionshallaffectthefiscalprivilegesofmembersofdiplomaticmissionsor consularpostsunderthegeneralrulesofinternationallaworundertheprovisionsofspecialagreements.

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Article28
MISCELLANEOUSRULES

1. With respect to pooled investment accounts or funds (as for instance the existing Foreign Capital Investment Fund in Chile), that are subject to a remittance tax and are required to be administered by aresidentinChile,theprovisionsofthisConventionshallnotbeinterpretedtorestrict imposition by Chile of the tax on remittances from such accounts or funds in respect of investment in assetssituatedinChile. 2. For the purposes of paragraph 3 of Article XXII (Consultation) of the General Agreement on Trade in Services, the Contracting States agree that, notwithstanding that paragraph, any dispute betweenthemastowhetherameasurefallswithinthescopeofthisConventionmaybebroughtbefore the Council for Trade in Services, as provided by that paragraph, only with the consent of both Contracting States. Any doubt as to the interpretation of this paragraph shall be resolved under paragraph 3 of Article 25 or, failing agreement under that procedure, pursuant to any other procedure agreedtobybothContractingStates.

3. Nothing in this Convention shall affect the application of the existing provisions of the Chilean legislation DL 600 (Foreign Investment Statute) as they are in force at the time of signature of this Convention and as they may be amended from time to time without changing the general principle hereof. 4. Considering that the main aim of the Convention is to avoid international double taxation, the ContractingStatesagreethat,intheeventtheprovisionsoftheConventionareusedinsuchamanner as to provide benefits not contemplated or not intended, the competent authorities of the Contracting States shall, under the mutual agreement procedure of Article 25,recommendspecificamendmentsto bemadetotheConvention.TheContractingStatesfurtheragreethatanysuchrecommendationwillbe considered and discussed in an expeditious manner with a view to amending the Convention, where necessary. 5. NothinginthisConventionshallaffectthetaxationinChileofaresidentinNorwayinrespectof profitsattributabletoapermanentestablishmentsituatedinChile,underboththefirstcategorytaxand theadditionaltaxbutonlyaslongasthefirstcategorytaxisdeductibleincomputingtheadditionaltax.

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CHAPTERVII FINALPROVISIONS

Article29
ENTRYINTOFORCE 1. Each of the Contracting States shall notify the other through diplomatic channels of the completion of the procedures required by law for the bringing into force of this Convention. This Conventionshallenterintoforceonthedateofthelaterofthesenotifications. 2. TheprovisionsofthisConventionshallhaveeffect: (a) inChile,

in respect of taxes on income obtained and amounts paid, credited to an account, put at the disposal or accounted as an expense, on or after the first day of January in the calendar year nextfollowingthatinwhichthisConventionentersintoforceand (b) inNorway,

in respect of taxes on income or on capital relating to the calendar year (including accounting periodsbeginninginanysuchyear)nextfollowingthatinwhichtheConventionentersintoforce andsubsequentyears.

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Article30
TERMINATION 1. This Convention shall continue in effect indefinitely but either Contracting State may, on or before the thirtieth day of June in any calendar year beginning after the year in which the Convention entersintoforce,givetotheotherContractingStateanoticeofterminationinwritingthroughdiplomatic channels. 2. TheprovisionsofthisConventionshallceasetohaveeffect: (a) inChile,

in respect of taxes on income obtained and amounts paid, credited to an account, put at the disposal or accounted as an expense, on or after the first day of January in the calendar year nextfollowingthatinwhichthenoticeisgivenand (b) inNorway,

in respect of taxes on income or on capital relating to the calendar year (including accounting periodsbeginninginanysuchyear)nextfollowingthatinwhichthenoticeisgiven

IN WITNESS WHEREOF the undersigned, duly authorised to that effect, have signed this Convention. DONEinduplicateat ,this

in the Spanish, Norwegian and English languages, all three texts being equally authentic. In case of divergencebetweentheSpanishandNorwegiantexts,theEnglishtextshallprevail.

FORTHEGOVERNMENT OFTHEREPUBLICOFCHILE

FORTHEGOVERNMENT OFTHEKINGDOMOFNORWAY

32

PROTOCOLTOTHECONVENTIONBETWEEN THEREPUBLICOFCHILE AND THEKINGDOMOFNORWAY FORTHEAVOIDANCEOFDOUBLETAXATIONANDTHEPREVENTIONOFFISCALEVASION WITHRESPECTTOTAXESONINCOMEANDONCAPITAL

OnsigningtheConventionfortheavoidanceofdoubletaxationandthepreventionoffiscalevasionwith respect to taxes on income and on capital between the Republic of Chile and the KingdomofNorway, thesignatorieshaveagreedthatthefollowingprovisionsshallformanintegralpartoftheConvention. 1. Article7

It is understood that the provisions of paragraph 3 of Article 7 shall apply only if the expenses can be attributedtothepermanentestablishmentinaccordancewiththeprovisionsofthetaxlegislationofthe ContractingStateinwhichthepermanentestablishmentissituated. 2. Article8

Whenever companies from different countries have agreed to carry on an air transportation business togetherintheformofaconsortium,theprovisionsofparagraphs1and2shallapplyonlytosuchpartof theprofitsoftheconsortiumasrelatestotheparticipationheldinthatconsortiumbyacompanythatisa residentofaContractingState. 3. Article10

InthecaseofChile,theprovisionsofparagraph2ofArticle10(Dividends)oftheConventionshallnotlimit applicationoftheadditionaltaxprovidedthatthefirstcategorytaxisfullycreditableincomputingtheamount ofadditionaltaxtobepaid.

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4.

Articles11and12

If in any Agreement or Convention concluded by Chile with a third state, being a member of the Organisation for Economic Cooperation and Development, Chile would agree to exempt interest or royalties (either generally or for specific items of interest or royalties) arising in Chile from tax or to reduce the rate of tax provided in paragraph 2 of Articles 11 or 12, respectively, such exemption or reduced rate shall automatically apply under the same conditions as if it had been specified in this Convention. 5. Article24

NothinginArticle24ofthisConventionshallapplytothecontinuation,renewaloramendmentofanon conformingprovisionofataxationmeasureexistingatthetimeofsigningtheConvention. 6. Article26

WhereinformationhasbeenexchangedundertherulesofArticle26,theinformationmayalsobemade available,underthesameconditionsandrestrictions,forthepurposesofanyothertaxesimposedinthe Statethathasreceivedtheinformation. INWITNESSWHEREOFtheundersigned,dulyauthorisedtothateffect,havesignedthisProtocol. DONEinduplicateat ,this

in the Spanish, Norwegian and English languages, all three texts being equally authentic. In case of divergencebetweentheSpanishandNorwegiantexts,theEnglishtextshallprevail.

FORTHEGOVERNMENT OFTHEREPUBLICOFCHILE

FORTHEGOVERNMENT OFTHEKINGDOMOFNORWAY

34