If a Norwegian limited partnership which has no Canadian partners qualifies as a resident of Norway for purposes of the Canada-Norway Income Tax Convention, rental payments derived from the use of moveable property in Canada will be treated as business profits provided that the income is taxed in the partnership. If the income of the limited partnership is taxed in the hands of the Norwegian partners, it will be a question of fact whether or not the partners are carrying on a business and whether that business is being carried on in Canada through a permanent establishment. Where a partner of the Norwegian limited partnership is a resident of a country other than Norway or Canada, the articles of the appropriate tax convention will apply.
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