On 24 January 2025, the Norwegian Cabinet approved the pending protocol to the 2009 income tax treaty with Qatar. The protocol, signed 4 September 2024, is the first to amend the treaty and includes the following changes: The title and preamble are replaced in line with OECD BEPS standards; Paragraph 1 of Article 21 (Offshore Activities) is replaced to provide that the provision of Article 21 shall apply notwithstanding any other provision of the treaty, subject to Article 23 (Limitation on Benefits); Article 23 (Limitation on Benefits) is updated with the addition of a principal purpose test, which provides that...