Artikel 16

1. Directors’ fees or similar remuneration derived by a resident of the Netherlands in his capacity as a member of the board of directors or of a similar organ of a company which is a resident of Norway may be taxed in Norway.
2. Directors’ fees or other remuneration derived by a resident of Norway in his capacity as a “bestuurder” or a “commissaris” of a company which is a resident of the Netherlands may be taxed in the Netherlands.
3. Where the remuneration mentioned in paragraphs 1 or 2 is derived by a person who exercises activities of a regular and substantial character in a permanent establishment situated in the State other than the State of which the company is a resident and the remuneration is deductible in determining the taxable profits of that permanent establishment, then, notwithstanding the provisions of paragraphs 1 or 2 of this Article, the remuneration, to the extent to which it is so deductible, shall be taxable only in the State in which the permanent establishment is situated.