As provided in paragraph 3, of Article 10 (Dividends) of the Canada-Norway Tax Convention, Competent Authorities of Canada and Norway have agreed that:

1. Paragraph 3 of Article 10 of the Convention will apply to exempt dividends from source taxation where the dividends are received by a Contracting State or a political subdivision or local authority thereof, or to any wholly-owned agency or instrumentality of that State, political subdivision or local authority provided that the State, political subdivision, local authority, wholly-owned agency or instrumentality:

• owns less than 25 per cent of the payer of the dividends, and
• the funds invested result from the performance of functions of a governmental nature.

2. For the purposes of this agreement, paragraph 3 of Article 10 shall apply to:

• in the case of Norway to:
  
  1. the Central Bank of Norway (Norges Bank);
  2. the Government Pension Fund - Global (Statens Pensjonsfond - Utland);
  3. the municipality of Bærum (Bærum Kommune); and
     
• in the case of Canada to:
  
  1. the Canada Pension Plan Investment Board; and
  2. the Canada Pension Plan.

3. It is understood that this agreement shall apply to dividends paid beginning January 1, 2010.