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Protocol 1994 Norway - Brazil

St prp nr 63 93-94

Protocol supplementing the "convention between the federative republic of Brazil and the kingdom of Norway for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital" signed in Brasilia on 21 august 1980

The Government of the Federative Republic of Brazil and the Government of the Kingdom of Norway,

Desiring to supplement the "Convention between the Federative Republic of Brazil and the Kingdom of Norway for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital", signed in the city of Brasilia, on August 21, 1980,

Considering, in accordance with Paragraph 3 (b) of the Protocol to the Convention, that the tax rate limitations in the provisions of Paragraphs 2 and 5 of Article 10, Paragraphs 2 and 3 of Article 11, Paragraph 2 (b) of Article 12, and as well as Paragraph 4 of Article 24 of the Convention have been ineffective since January 1st, 1992, and that the process of a revision of the whole Convention has been initiated,

Have agreed that the above mentioned provisions of the Convention shall be in force with the selfsame content, from the day of the entry into force of the present Protocol.

The present Protocol shall enter into force on the thirtieth day after the date of exchange of instruments of ratification and shall have effect as respects income derived during the taxable years beginning on or after the first day of January in the calendar year next following that in which the present Protocol enters into force.

The present Protocol shall continue in force for three years, beginning in the year it has effect for the first time.

It is understood that the period comprised between January 1st, 1992, and the day of the entry into force of the present Protocol is not covered by its provisions.

In Witness Whereof the Undersigned being duly authorized thereto by their respective Governments, have signed the present Protocol.

Done in duplicate at Brasilia on 12 July 1994, in the Portuguese, Norwegian and English languages, all three texts being equally authentic. In case of any divergence of interpretation the English text shall prevail.

For the GovernmentFor the Government

of the Kingdomof the Federative

of Norway:Republic of Brazil:

Herbert LinderCelso L. N. Amorim

(sign.)(sign.)