Publication 901 - U.s. Tax Treaties - Internal Revenue Service Page 11
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34Norway
Do not have a fixed base regularly availa
Pay received by employees who are mem
ble to them in the United States for per
bers of the regular complement of a ship or air
Income that residents of Norway receive for
forming their services.
craft operated by a resident of Poland in inter
performing personal services as independent
national traffic is exempt from U.S. tax.
If they have a fixed base available in the United
contractors or selfemployed individuals (inde
States, they are taxed only on the income attrib
pendent personal services) in the United States
Portugal
utable to the fixed base. There is no dollar limit
during the tax year is exempt from U.S. income
for condition (2) if the contractor is a resident of
tax if the residents:
Income that residents of Portugal receive for
a country other than the United States.
Are present in the United States for no
performing personal services as independent
more than 182 days during the tax year,
contractors or selfemployed individuals (inde
Income that residents of the Philippines re
and
pendent personal services) in the United States
ceive for personal services performed in the
Do not maintain a fixed base in the United
is exempt from U.S. income tax if the residents:
United States as employees (dependent per
States for more than 182 days during the
Are in the United States for no more than
sonal services) is exempt from U.S. income tax
tax year.
182 days in any 12month period, and
if the residents meet three requirements.
Do not have a fixed base regularly availa
They are in the United States for no more
If they do not meet requirement (2), they are
ble to them in the United States for per
than 89 days during the tax year.
taxed only on the income attributable to the
forming the activities.
They are employees of a resident of the
fixed base.
Philippines or of a permanent establish
If they have a fixed base available, they are
ment maintained in the Philippines.
This exemption does not apply to residents
taxed only on the income attributable to the
Their income is not borne by a permanent
of Norway who are public entertainers (theater,
fixed base.
establishment that the employer has in the
motion picture, or television artists, musicians,
United States.
or athletes) if they are in the United States for
Income that residents of Portugal receive for
more than 90 days during the tax year or their
employment in the United States (dependent
Pay received by an employee of a resident
pay for services as public entertainers is more
personal services) is exempt from U.S. income
of the Philippines for personal services per
than $10,000 during the tax year.
tax if the following three requirements are met.
formed as a member of the regular complement
The resident is in the United States for no
of a ship or an aircraft operated in international
Income that residents of Norway receive for
more than 183 days in any 12month pe
traffic by a resident of the Philippines is exempt
labor or personal services performed in the Uni
riod.
from U.S. tax.
ted States as employees (dependent personal
The income is paid by, or on behalf of, an
services) is exempt from U.S. income tax if the
employer who is not a U.S. resident.
These exemptions do not apply to income
residents meet three requirements.
The income is not borne by a permanent
residents of the Philippines receive for perform
They are in the United States less than 183
establishment or fixed base that the em
ing services (both independent and dependent
days during the tax year.
ployer has in the United States.
personal services) in the United States as en
They are employees of a resident of Nor
tertainers, such as theater, motion picture, ra
way or of a permanent establishment of a
Income received by a resident of Portugal
dio, or television artists, musicians, or athletes,
resident of a state other than Norway if the
for employment as a member of the regular
if the income is more than $100 a day or $3,000
permanent establishment is situated in
complement of a ship or aircraft operated in in
for the tax year. Regardless of these limits, in
Norway.
ternational traffic is exempt from U.S. tax.
come of Philippine entertainers is exempt from
Their income is not borne by a permanent
U.S. tax if their visit to the United States is sub
establishment that the employer has in the
stantially supported or sponsored by the Philip
United States.
These exemptions do not apply to income
pine Government and the entertainers are certi
residents of Portugal receive as public enter
fied as qualified for this exemption by the
tainers (such as theater, motion picture, radio,
The exemption does not apply to a resident
Philippine competent authority.
or television artists, or musicians) or athletes if
of Norway who performs services as an em
that income, including reimbursed expenses, is
ployee aboard a ship or an aircraft operated by
Poland
more than $10,000. The income of Portuguese
a United States resident in international traffic
entertainers and athletes is exempt from U.S.
or in fishing on the high seas if the resident of
tax if their visit to the United States is substan
Norway is a member of the regular complement
Income that residents of Poland receive for per
tially supported by public funds of Portugal or its
forming personal services as independent con
of the ship or aircraft.
political or administrative subdivisions.
tractors or selfemployed individuals (independ
ent personal services) in the United States is
Pakistan
exempt from U.S. income tax if they are in the
These exemptions do not apply to directors'
United States for no more than 182 days during
fees and similar payments received by a resi
Residents of Pakistan who perform personal
the tax year.
dent of Portugal for services performed outside
services (including professional services) for or
of Portugal as a member of the board of direc
on behalf of a resident of Pakistan while in the
Income that residents of Poland receive for
tors of a company that is a resident of the Uni
United States for no more than 183 days during
labor or personal services performed as em
ted States.
the tax year are exempt from U.S. income tax
ployees (dependent personal services), includ
on the income from the services if they are sub
ing services performed by an officer of a corpo
ject to Pakistani tax.
Romania
ration or company, in the United States during
the tax year is exempt from U.S. income tax if
Philippines
Income that residents of Romania receive for
the residents meet three requirements.
performing personal services as independent
They are in the United States for no more
contractors or selfemployed individuals (inde
Income that residents of the Philippines receive
than 182 days during the tax year.
pendent personal services) in the United States
for performing personal services as independ
Their income is paid by or on behalf of an
during the tax year is exempt from U.S. income
ent contractors or as selfemployed individuals
employer who is not a U.S. resident.
tax if the residents:
(independent personal services) in the United
Their income is not borne by a permanent
Are present in the United States for no
States during the tax year is exempt from U.S.
establishment that the employer has in the
more than 182 days during the tax year,
income tax if the residents:
United States.
and
Are in the United States for no more than
Do not maintain a permanent establish
89 days during the tax year,
ment in the United States with which the in
Earn gross income for those services that
come is effectively connected.
is not more than $10,000 for the tax year if
the income is from U.S. contractors, and
Publication 901 (September 2016)
Page 11
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