This document is the Double Taxation Relief (Kenya/Norway) Arrangements Notice 1973, setting out a Convention between the Government of the Republic of Kenya and the Government of the Kingdom of Norway for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital.Taxes Covered (Article 2):

• Kenya Tax includes income tax and the graduated personal tax.

• Norwegian Tax includes national and municipal taxes on income (including contributions to the tax equalization fund) and capital, national dues on the salaries of non-resident artistes, the special tax in aid of developing countries, municipal tax on immovable property, and the seamen's tax.

• The Convention also applies to any identical or substantially similar taxes subsequently imposed.

Taxation of Specific Income Types:

• Dividends (Article 10): Tax in the company's resident state (source state) shall not exceed:

  • 15% of the gross amount if the recipient is a company owning at least 25% of the voting shares for the preceding six months.

  • 25% of the gross amount in all other cases.

• Interest (Article 11): Tax in the source state shall not exceed 20% of the gross amount of interest. Certain payments to the government, a political subdivision, or the Central Bank of the other state are exempt.

• Royalties (Article 12): Tax in the source state shall not exceed 20% of the gross amount of the royalties.

• Management or Professional Fees (Article 14): Tax in the source state shall not exceed 20% of the gross amount.

Elimination of Double Taxation (Article 25):

• Kenya: Allows a credit against Kenyan tax for Norwegian tax paid, up to the amount of Kenyan tax attributable to the income from Norway.

• Norway: Generally exempts income or capital that may be taxed in Kenya, or allows a deduction from tax for the tax paid in Kenya for income under Articles 8, 10, 11, 12, or 14.

Entry into Force (Article 30):The Convention came into force upon the necessary steps in both Kenya and Norway being completed, with effect:

• In respect of income arising for the year of income 1972 and subsequent years.

• In respect of capital assessed for the year of income 1972 and subsequent years.

  The Convention was done at Nairobi on December 13, 1972.