AGREEMENT BETWEEN GRENADA AI{D 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 I Objectand scope the agreement of Thecompetent authorities the Contracting of Parties shallprovideassistance throughexchange information of that is foreseeably relevant the administration to and enforcement the domestic of lawsof the Contracting Parties concerning taxescovered this by Agreement. Suchinformationshallincludeinformation that is foreseeably relevant the to determination, assessment collection suchtaxes, recovery enforcement tax and of the and of claims,or the investigation prosecution tax matters. or of Informatidn shallbe exchanged in accordance theprovisions this Agreement shallbetreated with of and as'confidential the in providedin Article 8. Therightsandsafeguards manner secured persons the lawsor to by practice the requested administrative of Partyremainapplicable the extentthatthey do not to undulyprevent delayeffectiveexchange information. or of

Article 2 Jurisdiction which is neitherheld to Partyis not obligated provideinformation A Requested who arewithin its territorial or nor by its authorities in the possession controlof persons jurisdiction.

Article 3 Taxescovered are of 1. Thetaxeswhich aresubject this Agreement taxesof everykind anddescription of at Parties the dateof signature the Agreement. by imposed the Contracting afterthe dateof signature shallalsoapptyto anyidenticaltaxesimposed 2. This Agreement shallalso in of the Agreement additionto or in placeof the existingtaxes. This Agreement of afterthe dateof signature the Agreement similartaxesimposed applyto any substantially of authorities the Contracting in additionto or in placeof the existingtaxesif the competent or maybe expanded modifiedby mutual the Furthermore, taxescovered so Parties agree. Thecompetent of in Parties the form of an exchange letters. of agreement the Contracting to changes the shallnotiff eachotherof anysubstantial Parties of authorities the Contracting by covered the Agreement, measures informationgathering taxationandrelated Article 4 Definitions
t

1.ForthepurposesofthisAgreement,un1essotherwisedefined: as Norway or Grenada the context Party"means a) theterm "Contracting requires; the means countryof Grenada;, b) theterm "Grenada" the the c) theterm "Norway"means Kingdomof Norway,andincludes land territory andinternalwaters,the territorial seaandthe areabeyondthe tenitorial and legislation in to seawherethe Kingdomof Norway,according Norwegian

with law, accordance international may exercise rightswith respect the her to seabed subsoilandtheir naturalresources; termdoesnot comprise and the ("biland"); Svalbard, MayenandtheNorwegian Jan dependencies d) theterm "competent authority"means: (i) in the case Grenada, Ministerof Finance his authorised of the or representative; (ii) in Norway,theMinisterof Finance the Minister'sauthorised or representative; e) theterm "person"includes individual,a company anyotherbodyof an and persons; f) theterm'ocompany" means body corporate anyentitythat is treated any or as a bodycorporate tax purposes; for g) theterm "publicly tradedcompany" means company any whoseprincipal providedits listedshares classofsharesis listedon a recognised stockexchange canbe readilypurchased soldby thepublic. Shares be purchased sold or can or "by the public" if thepurchase saleof shares not implicitly or explicitly or is restricted a limited groupof investors; to h) theterm "principalclassof shares" means classor classes shares the of representing majorityof thevotingpowerandvalueof the company; a i) the term "recognised stockexchange" means stockexchange any agreed upon by the competent authorities the Contracting of Parties; j) theterm "collectiveinvestment fund or scheme" means pooledinvestment any vehicle,irrespective legalform. Theterm "public collectiveinvestment of fund or scheme" means collectiveinvestment providedthe units, any fund or scheme in shares otherinterests the fund or scheme be readilypurchased, or or can sold redeemed the public.Units,shares otherinterests the fund or scheme by or in canbe readilypurchased, or redeemed the public" if the purchase, sold "by sale or redemption not implicitly or explicitly restricted i limlted groupof is to investors; k) theterm "tax" means tax to which theAgreement any applies; l) theterm "applicant Parfy"means Contracting the Partyrequesting information; Party"means Contracting m) the term "requested the Partyrequested provide to information:

or gathering lawsandadministrative measures" means n) the term ooinformation judicial procedures enable Contracting Partyto obtainandprovidethe a that requested information; or any o) the term "information"means fact,statement recordin anyform whatever; tax involvingintentional p) theterm "criminaltax matters" means matters underthe criminallawsof the applicant which is liableto prosecution conduct party; as q) theterm "criminal laws" means criminallawsdesignated suchunder all in contained thetax laws,the criminal law of domestic irrespective whether codeor otherstatutes. Party,anyterm at of 2. As regards application this Agreement anytime by a Contracting the that requires, havethe meaning it hasat the not defined thereinshall,unless contextotherwise tax underthe applicable lawsof thatParty thattime underthe law of that Purty,anymeaning givento the termunderotherlawsof that Party. prevailingovera meaning

Article 5 Exchange Information Upon Request of for information Partyshallprovideuponrequest 1. The competent authorityof the requested to withoutregard referred in Article 1. Suchinformationshallbe exchanged to thepurposes would constitute crimeunderthe lawsof the a whether conduct the beinginvestigated Party. in Partyifsuch conduct occurred the requested requested Partyis not authorityof therequested of in 2. If the information the possession the competent that for it sufficientto enable to complywith the request informatiori, Partyshalluseall Pariywith the information gathering to measures providethe applicant relevant information for Partymay not needsuchinforrnation its own that requested, notwithstanding the requested tax purposes.

Party,the competent authorityof an applicant by requested the competent 3. If specifically Partyshallprovideinformationunderthis Article, to the extent authorityof the requested

laws,in the form of depositions witnesses authenticated of and allowable underits domestic copiesof originalrecords.

for specified 4. EachContracting Parfyshallensure its competent that authorities thepurposes havethe authorityto obtainandprovideuponrequest: in Article 1 of the Agreement, heldby banks, otherfinancialinstitutions, anyperson and acting a) information includingnominees trustees; in an agency fiduciarycapacity or and partnerships, regarding ownership companies, the of trusts, b) information including,within the constraints of foundations, "Anstalten"andotherpersons, information all suchpersons anownership in chain;in Article 2, ownership on on trustees beneficiaries; in the and and the case trusts,information settlors, of informationon founders, members the foundation case foundations, of of Further, Agreement this doesnot create obligation an councilandbeneficiaries. Parties obtainor provideownership information with on the Contracting to to or fundsor respect publiclytradedcompanies public collectiveinvestment suchinformation be obtained can without giving riseto schemes unless disproportionate diffrculties.

Partyshallprovidethe following information to 5. The competent authorityof the applicant Partywhenmakinga request information for under the competent authorityof the requested relevance the information the request: of to theAgreement demonstrate foreseeable to the or a) the identityof the person underexamination investigation; includingits natureandthe form in b) a statement the informationsought of Partywishes receive information to the from therequested whichthe applicant Party; for is c) thetax purpose which the information sought; requested held in the requested for is d) grounds believingthat the information Partyor is in the possession controlof a person or within tle jurisdictionof the Purty; requested of believed be in to e) to the extentknown,the nameandaddress anyperson possession therequested of information; is that f) a statement the request in conformitywith the law andadministrative practices the applicant P*ty, that if the requested information of waswithin the jurisdictionof the applicant Partythenthe competent authorityof the applicant

underthe lawsof the applicant Partywould be ableto obtainthe information practice that it is in and of Partyor in the normalcourse administrative conformitywith this Agreement; in all available its own Partyhaspursued means g) a statement the applicant that thosethatwould give riseto except territoryto obtainthe information, diffi disproportionate culties. as information Partyshallforwardthe requested authorityof the requested 6. Thecompetent the a Party.To ensure promptresponse, competent promptlyaspossible the applicant to Partyshall: authorityof the requested authorityof the in a) Confirmreceiptof a request writing to the competent Partyof authorityof the applicant Partyandshallnotifu the competent applicant if in deficiencies therequest, any,within 60 daysof the receiptof the request. to Partyhasbeenunable obtain authorityof the requested b) If the competent includingif within 90 daysof receiptof the request, andprovidethe information to or the in obstacles furnishing information it refuses fumishthe it encounters the Party,explaining inform the applicant it information, shallimmediately for or for reason its inabiliff. thenatureof the obstacles thereasons its refusal.

Article 6 Abroad Tax Examinations authorityof the other of Partymay allow representatives the competent l. A Contracting Partyto interviewindividuals Partyto entertheterritoryof the first-mentioned Contracting concerned. The of with thewrittenconsent the persons records andexamine authorityof the Party authorityof the second-mentioned shallnotify the competent competent with tG individualsconcerned. Partyof the time andplaceof the meeting first-mentioned Party,the authorityof oneContracting of 2. Atthe request the competent of Partymay allow representatives the competent authorityof the otherContracting part at Partyto bepresent the appropriate of a tax authorityof the first-mentioned competent Party. in examination the second-mentioned

referred in paragraph2 acceded the competent to is to, authorityof the 3. If the request notiff the competent Partyconducting examination the shall,assoonaspossible, Contracting the authorityof the otherPartyaboutthetime andplaceof the examination, authorityor required by to and and offrcialdesignated carryout the examination theprocedures conditions Partyfor the conduct the examination. decisions of All with respect the to the first-mentioned conduct the tax examination of shallbe madeby the Partyconducting examination. the

Article 7 Possibility Declininga Request of

1.The requested Partyshallnot berequired obtainor provideinformation to thatthe applicant or Partywould not be ableto obtainrmderits own lawsfor purposes the administration of Partymay decline of authorityof therequested enforcement its own tax laws.Thecompetent wherethe request not madein conformitywith this Agreement. is to assist

of shallnot impose a Contracting on Partythe obligation to 2.The provisions this Agreement which would disclose trade,business, industrial, or supplyinformation any commercial professional or Notwithstanding foregoing, the information thetype of secret tradeprocess. referred in Article 5, paragraph4 to shallnot betreated sucha secret tradeprocess as or it the merelybecause meets criteriain thatparagraph.

of shallnot impose a Contracting on Partythe obligationto 3. Theprovisions this Agreement whichwould revealconfidential communications between a obtainor provideinformation, solicitoror otheradmitted legalrepresentative clientandan attorney, wheresuch communications are: (a) produced the purposes seeking providinglegaladviceor for of or (b) produced the pu{poses usein existingor contemplated for of legal proceedings.

for 4. Therequested Partymay declinea request informationif the disclosure the of information wouldbe contraryto publicpolicy (ordrepublic).

on 5. A request informationshallnot be refused the groundthatthetax claimgiving riseto for therequest disputed. is

6. Therequested Partymay declinea request information the information requested for if is by the applicant Partyto administer enforce provisionof the tax law of the applicant or a ParW, anyrequirement or which discriminates connected therewith, against nationalof the a requested Partyascompared with a nationalof the applicant Partyin the same circumstances.

Article 8 Confidentialitv

Any information received a Contracting by Partyunderthis Agreement shallbetreated as (includingcourtsand confidential may be disclosed or and only to persons authorities administrative bodies)in thejurisdictionof the Contracting Partyconcerned the with assessment collectionof, the enforcement prosecution respect or the determination or or in of of appeals relationto, the taxescovered this Agreement.Suchpersons authorities in by or Theymay disclose informationin shallusesuchinformationonly for suchpurposes. the public courtproceedings in judicial decisions.The information or maynot be disclosed to anyotherperson entity or authorityor anyotherjurisdictionwithoutthe express or written consent the competent Party. of authorityof the requested

Article 9 Costs Incidence ofcosts incurredin providingassistance be agreed the shall by Contracting Parties.

Article 10 procedure Mutual agreement

1. Wheredifficultiesor doubtsarisebetween Contracting the Parties regarding the implementation interpretation this Agreement, respective or of the competent authorities shall endeavour resolve matterby mutualagreement. to the

2. In additionto the agreements referred in paragraph the competent to 1, authorities the of Contracting may mutuallyagree theprocedures be usedunderArticles5 and6. on to Parties

3. The competent authorities the Contracting of Parties may communicate eachother with directlyfor purposes reaching of agreement underthis Article.

Article 11 Entry into Force 1. Eachof the Contracting Parties shallnotify the otherin writing of the completion the of procedures required its law for the entryinto forceof this Agreement. by 2.The Agreement shallenterinto forceon the thirtiethdayafterthe receiptof the laterof these notifications shallthereupon and haveeffect a) b) for criminaltax matters, that date; on for all othermatters covered Article 1, for taxable in periods beginning or on afterthe first dayof January the yearnext following the dateon whichthe of Agreement enters into force,or wherethereis no taxable period,for all charges to tax arisineon or afterthat date.

Article 12 Termination L This Agreement shallremainin forceuntil terminated a Contracting by Parfy.Either Contracting Partymay terminate Agreement giving writtennoticeof termination the the by to otherContracting Party.In suchcase, Agreement the shallcease haveeffecton the first day to of the monthfollowing the endof the periodof six monthsafterthe dateof receiptof notice of termination the otherContracting by Party.

2. In the eventof termination, both Contracting Parties shallremainboundby &e provisions of Article 8 with respect anyinformationobtained to underthe Agreement.

In witness whereofthe undersigned beingduly authorised thereto havesigned Agreement. the

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FOR GRJNADA:

F'ORTHE KINGDOM OF'NORWAY:

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