The US Internal Revenue Service (IRS) has issued Announcement 2024-42 on 9 December 2024 in which it notified taxpayers the US and Norway has entered a competent authority arrangement (CAA) in accordance to the paragraph 2 of Article 27 (mutual agreement procedure (MAP)) of the US-Norway income tax treaty.
The US and Norway signed the income tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and property on 3 December 1971, which was amended by the protocol signed on 19 September 1980.
As per the CAA, the competent authorities confirm that Article 20 (Investment or Holding Companies) is not applicable to a US investment company that qualifies as a Regulated Investment Company pursuant to sections 851 (Definition of regulated investment company) and 852 (Taxation of regulated investment companies and their shareholders) of the Internal Revenue Code.
