Law (2015:666) On Tax Agreement Between Sweden And The United Kingdom And Northern Ireland

Original Language Title: Lag (2015:666) om skatteavtal mellan Sverige samt Storbritannien och Nordirland

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Read the untranslated law here: http://rkrattsbaser.gov.se/sfst?bet=2015:666

/Entry into force: 12/31/2015

section 1 of the agreement for the avoidance of double taxation and

Prevention of tax evasion with respect to taxes on income

and on the capital gain as Sweden and the United Kingdom and

Northern Ireland signed on 26 March 2015 will apply as law

here in the country. The agreement is drawn up in English. The English

text and an English translation of the agreement evidenced by

the annex to this law.



section 2 of the tax rules of the agreement shall apply only to the

some of these causes restriction of the tax liability in

Sweden that would otherwise exist.



Transitional provisions



2015:666



1. This law shall enter into force on the day on which the Government determines.



2. The law shall apply in the case of



a) withholding taxes, on amounts paid or tillgodoförs the

1 January of the year immediately following the date on which the Act

enters into force, or later,



(b)) other taxes on income, the tax levied on

tax year that begins on 1 January of the year following

immediately following the day on which the Act comes into force or later,



c) arbitration under article 23 of the agreement, from

the date on which the Act comes into force regardless of the tax year

the case concerns, and



d) information exchange under article 24 of the agreement, at the request

produced on the day on which the Act comes into force or later,

regardless of which year the tax claim is

attribute.

3. A case may not be the subject of

arbitration under 2 c) earlier than three years after the Act's

date of entry into force.



4. by law repeals Act (1983:898) if

double taxation treaties between Sweden and the United Kingdom

and Northern Ireland.



5. The repealed Act applies, however, remains concerned about

the following:



a) withholding taxes, on amounts paid or tillgodoförs before

on 1 January of the year immediately following the day on which the Act

enters into force.



(b)) Other taxes on income, the tax levied on

tax years beginning before 1 January of the year

immediately after the day on which the Act comes into force.



(c)), article 18 and article 19 point 2 of the annex on a physical

person immediately before the entry into force of the agreement of 26

March 2015 was the recipient of the payment covered by the said

provisions and that, in accordance with article 29 of the agreement

paragraph 5, chosen to these older rules, and not

the provisions of article 17 of the agreement, shall apply to such

payout. The older provisions shall apply from

with the year in which the choice is made until the election is revoked. When a

the election is revoked, no new selections can be made.



Annex



Convention between the Kingdom of Sweden and the United

Kingdom of Great Britain and Northern Ireland for the

avoidance of double taxation and the prevention of fiscal

evasion with respect to taxes on income and on capital

gains

The Government of the Kingdom of Sweden and the

The Government of the United Kingdom of Great Britain and

Northern Ireland;



Desiring to conclude a Convention for the avoidance of double

taxation and the prevention of fiscal evasion with respect to

taxes on income and on capital gains;



Have agreed as follows:



Article 1



Persons covered



1. This Convention shall apply to persons who are residents

of one or both of the Contracting States.



2. For the purposes of this Convention, income, profit or

gain derived by or through an entity or arrangement that is

treated as wholly or partly fiscally transparent under the

tax law of either Contracting State shall be considered to be

income, profit or gain of a resident of a Contracting State

but only to the extent that the income, profit or gain is

treated, for the purposes of taxation by that State, as the

income, profit or gain of a resident of that State. In no

case shall the provisions of this paragraph be construed so

as in any way to restrict a Contracting State's right to tax

the income, profit or gain of the residents of that State.



Article 2



Taxes covered



1. This Convention shall apply to taxes on income and on

capital gains imposed on behalf of a Contracting State or of

its political subdivisions or local authorities, irrespective

of the manner in which they are levied.



2. There shall be regarded as taxes on income and on capital

gains all taxes imposed on total income or on elements of

income, including taxes on gains from the alienation of

movable or immovable property, as well as taxes on capital

appreciation.



3. The taxes to which the Convention shall apply are:



a) in Sweden:



(i) the national income tax (State income tax);



(ii) the withholding tax on dividends (withholding tax);



(iii) the income tax on non-residents (the Special

income tax for non-residents);



(iv) the income tax on non-resident artistes and athletes

(the Special income tax for non-resident artists

etc.); and



(v) the municipal income tax (municipal

income tax);

(hereinafter referred to as "the Swedish

tax ");



(b)) in the United Kingdom:



(i) the income tax;



(ii) the corporation tax; and



(iii) the capital gains tax;



(hereinafter referred to as "United Kingdom tax").



4. The Convention shall apply also to any identical or

substantially similar taxes that are imposed after the date

of signature of the Convention in addition to, or in place

of, the taxes referred to in paragraph 3. The competent

authorities of the Contracting States shall notify each other

of any significant changes that have been made in their

taxation laws.



Article 3



General definition



1. For the purposes of this Convention, unless the context

otherwise requires:



a) the term "Sweden" means the Kingdom of Sweden and, when

used in a geographical sense, includes the national

territory, the territorial sea of Canada as well as other

the maritime areas over which Sweden in accordance with

international law exercises sovereign rights or

jurisdiction;



(b)) the term "United Kingdom" means Great Britain and Northern

Ireland but, when used in a geographical sense, means the

territory and territorial sea of Great Britain and Northern

Ireland and the areas beyond that territorial sea over which

Great Britain and Northern Ireland exercise sovereign rights

or jurisdiction in accordance with their domestic law and

international law;



(c)) the terms "a Contracting State" and "the other Contracting

State "mean Canada or the United Kingdom, as the context

requires;



d) the term "person" includes an individual, a company and

any other body of persons;



e) the term "company" means any body corporate or any entity

that is treated as a body corporate for tax purposes;



f) the term "enterprise" applies to the carrying on of any

business;



g) the terms "enterprise of a Contracting State" and

"enterprise of the other Contracting State" mean respectively

an enterprise carried on by a resident of a Contracting State

and an enterprise carried on by a resident of the other

Contracting State;



h) the term "international traffic" means any transport by a

ship or aircraft except when the ship or aircraft is operated

solely between places in a Contracting State and the

Enterprise that operates the ship or aircraft is not an

Enterprise of that State;



in) the term "competent authority" means:



(i) in Canada, the Minister of Finance, his authorised

representative or the authority which is designated as a

competent authority for the purposes of this Convention;



(ii) in the United Kingdom, the Commissioners for Her

Majesty's Revenue and Customs or their authorised

representative;



j) the term "national" means:



(i) in relation to Canada, any individual possessing the

nationality of Canada and any legal person, partnership or

Association deriving its status as such from the laws in

force in Sweden;



(ii) in relation to the United Kingdom, any British citizen,

or any British subject not possessing the citizenship of any

other Commonwealth country or territory, provided he has the

right of abode in the United Kingdom; and any legal person,

partnership or association deriving its status as such from

the laws in force in the United Kingdom;



k) the term "business" includes the performance of

professional services and of other activities of an

independent character.



2. As regards the application of the Convention at any time

by a Contracting State, any term not defined therein shall,

unless the context otherwise requires, have the meaning that

It has at that time under the law of that State for the

purposes of the taxes to which the Convention applies, any

meaning under the applicable tax laws of that State

prevailing over a meaning given to the term under other laws

of that State.



Article 4



Resident



1. For the purposes of this Convention, the term "resident

of a Contracting State "means any person who, under the laws

of that State, is liable to tax therein by reason of his

domicile, residence, place of management, place of

incorporation or any other criterion of a similar nature, and

also includes that State and any governmental body or agency,

political subdivision or local authority thereof. This term,

However, does not include any person who is liable to tax in

that State in respect only of income or capital gains from

sources in that State.



2. Where by reason of the provisions of paragraph 1 an

individual is a resident of both Contracting States, then his

status shall be determined as follows:



a) he shall be deemed to be a resident only of the State in

which he has a permanent home available to him; If he has a

a permanent home available to him in both States, he shall be

deemed to be a resident only of the State with which his

personal and economic relations are closer (centre of vital

interests);




b) if the State in which he has his centre of vital interests

cannot be determined, or if he does not have a permanent home

available to him in either State, he shall be deemed to be a

resident only of the State in which he has an habitual

abode;



c) if he has an habitual abode in both States or in neither

of them, he shall be deemed to be a resident only of the

State of which he is a national;



d) if he is a national of both States or of neither of them,

the competent authorities of the Contracting States shall

settle the question by mutual agreement.



3. Where by reason of the provisions of paragraph 1 a person

other than an individual is a resident of both Contracting

States, then the competent authorities of the Contracting

States shall endeavour to determine by mutual agreement the

Contracting State of which that person shall be deemed to be

a resident for the purposes of this Convention. In the

absence of a mutual agreement by the competent authorities of

the Contracting States, the person shall not be considered a

resident of either Contracting State for the purposes of

claiming any benefits provided by the Convention, except

those provided by Articles 21, 22 and 23.



Article 5



Permanent establishment



1. For the purposes of this Convention, the term "permanent

establishment "means a fixed place of business through which

the business of an enterprise is wholly or partly carried

on.



2. The term "permanent establishment" includes especially:



a) a place of management;



b) a branch;



c) an office;



d) a factory;



e) a workshop; and



f) a mine, an oil or gas well, a quarry or any other place of

extraction of natural resources.



3. A building site or construction, assembly or installation

project or supervisory activities in connection therewith

constitutes a permanent establishment only if it load more

than twelve months.



4. Notwithstanding the preceding provisions of this Article,

the term "permanent establishment" shall be deemed not to

include:



(a)) the use of facilities solely for the purpose of storage,

display or delivery of goods or merchandise belonging to the

Enterprise;



b) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of

storage, display or delivery;



c) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of

processing by another enterprise;



d) the maintenance of a fixed place of business solely for

the purpose of purchasing goods or merchandise or of

collecting information, for the enterprise;



e) the maintenance of a fixed place of business solely for

the purpose of carrying on, for the enterprise, any other

activity of a preparatory or auxiliary character;



f) an installation project carried on by an enterprise of a

Contracting State in the other Contracting State in

connection with delivery of machinery or equipment produced

by that enterprise;



g) the maintenance of a fixed place of business solely for

any combination of activities mentioned in subparagraphs (a))

to f), provided that the overall activity of the fixed place

of business resulting from this combination is of a

preparatory or auxiliary character.



5. Notwithstanding the provisions of paragraphs 1 and 2,

where a person – other than an agent of an independent status

to whom paragraph 6 applies-is acting on behalf of an

Enterprise and has, and habitually exercises, in a

Contracting State an authority to conclude contracts on

behalf of the enterprise, that enterprise shall be deemed to

have a permanent establishment in that State in respect of

any activities which that person undertakes for the

Enterprise, unless the activities of such person are limited

to those mentioned in paragraph 4 which, if exercised through

(a) a fixed place of business, would not make this fixed place of

business a permanent establishment under the provisions of

that paragraph.



6. An enterprise shall not be deemed to have a permanent

establishment in a Contracting State merely because it

carries on business in that State through a broker, general

Commission agent or any other agent of an independent status,

provided that such persons are acting in the ordinary course

of their business.



7. The fact that a company which is a resident of a

Contracting State controls or is controlled by a company

which is a resident of the other Contracting State, or which

carries on business in that other State (whether through a

permanent establishment or otherwise), shall not of itself

constitute either company a permanent establishment of the

other.



Article 6



Income from immovable property



1. Income derived by a resident of a Contracting State from

immovable property (including income from agriculture or

forestry) situated in the other Contracting State may be

taxed in that other State.



2. The term "immovable property" shall have the meaning which

It has under the law of the Contracting State in which the

property in question is situated. The term shall in any case

the include property accessory to immovable property, livestock

and equipment used in agriculture and forestry, rights to

which the provisions of general law respecting landed

property apply, buildings, usufruct of immovable property and

rights to variable or fixed payments as consideration for the

working of, or the right to work, mineral deposits, sources

and other natural resources; ships, boats and aircraft shall

not be regarded as immovable property.



3. The provisions of paragraph 1 shall apply to income

derived from the direct use, letting, or use in any other

the form of immovable property.



4. The provisions of paragraphs 1 and 3 shall also apply to

the income from immovable property of an enterprise.



Article 7



Business profits



1. Profits of an enterprise of a Contracting State shall be

taxable only in that State unless the enterprise carries on

business in the other Contracting State through a permanent

establishment situated therein. If the enterprise carries on

business as aforesaid, the profits that are attributable to

the permanent establishment in accordance with the provisions

of paragraph 2, may be taxed in that other State.



2. For the purposes of this Article and Article 21, the

profits that are attributable in each Contracting State to

the permanent establishment referred to in paragraph 1 are

the profits it might be expected to make, in particular in

its dealings with other parts of the enterprise, if it were a

separate and independent enterprise engaged in the same or

similar activities under the same or similar conditions,

taking into account the functions performed, assets used and

risks assumed by the enterprise through the permanent

establishment and through the other parts of the

Enterprise.



3. Where, in accordance with paragraph 2, a Contracting State

Adjusts the profits that are attributable to a permanent

establishment of an enterprise of one of the Contracting

States and taxes accordingly profits of the enterprise that

have been charged to tax in the other State, that other State

shall, to the extent necessary to eliminate double taxation

on these profits, make an appropriate adjustment if it agrees

with the adjustment made by the first-mentioned State; If the

other Contracting State does not so agree, the Contracting

States shall endeavour to eliminate any double taxation

resulting therefrom by mutual agreement.



4. Where profits include items of income or capital gains

which are dealt with separately in other Articles of this

Convention, then the provisions of those Articles shall not

be affected by the provisions of this Article.



Article 8



Shipping and air transport



1. Profits of an enterprise of a Contracting State from the

operation of ships or aircraft in international traffic shall

be taxable only in that State.



2. With respect to profits derived by the air transport

Consortium Scandinavian Airlines System (SAS) the provisions

of paragraph 1 shall apply only to such part of the profits

as corresponds to the participation held in that consortium

by SAS Sweden AB, the Swedish partner of SAS.



3. For the purposes of this Article, profits of an enterprise

of a Contracting State from the operation of ships or

aircraft in international traffic include:



a) profits from the rental on a bareboat basis of ships or

aircraft; and



b) profits from the use, maintenance or rental of containers

(including trailers and related equipment for the transport

of containers) used for the transport of goods or

merchandise;



where such rental or such use, maintenance or rental, as the

case may be, is incidental to the operation of ships or

aircraft in international traffic by that enterprise.



4. The provisions of paragraph 1 shall also apply to profits

from the participation in a pool, a joint business or an

international operating agency.



Article 9



Associated enterprises



1. The Where clause



a) an enterprise of a Contracting State participates directly

or indirectly in the management, control or capital of an

Enterprise of the other Contracting State, or



b) the same persons participate directly or indirectly in the

management, control or capital of an enterprise of a

Contracting State and an enterprise of the other Contracting

State,



and in either case conditions are made or imposed between the

the two enterprises in their commercial or financial relations

which differ from those which would be made between

independent enterprises, then any profits which would, but

for those conditions, have accrued to one of the enterprises,

but, by reason of those conditions, have not so accrued, may

be included in the profits of that enterprise and taxed

accordingly.



2. Where a Contracting State includes in the profits of an


Enterprise of that State – and taxes accordingly – profits on

which an enterprise of the other Contracting State has been

charged to tax in that other State and the profits so

included are profits which would have accrued to the

the enterprise of the first-mentioned State if the conditions

made between the two enterprises had been those which would

have been made between independent enterprises, then that

other State shall make an appropriate adjustment to the

the amount of the tax charged therein on those profits. In

determining such adjustment, due regard shall be had to the

other provisions of this Convention and the competent

authorities of the Contracting States shall if necessary

consult each other.



Article 10



Dividends



1. Dividends paid by a company which is a resident of a

Contracting State to a resident of the other Contracting

State may be taxed in that other State.



2. However, dividends paid by a company which is a resident

of a Contracting State may also be taxed in that State and

According to its laws, but if the beneficial owner of the

dividends is a resident of the other Contracting State, the

the tax so charged shall not exceed 5 per cent of the gross

the amount of the dividends. However, if the beneficial owner is

a company which controls, directly or indirectly, at least 10

per cent of the voting power of the company paying the

dividends, the dividends shall be exempt from tax in the

Contracting State of which the company paying the dividends

is a resident.



Notwithstanding the previous provisions of this paragraph,

where dividends are paid out of income (including gains)

derived directly or indirectly from immovable property within

the meaning of Article 6 by an investment vehicle which

distributes most of this income annually and whose income

from such immovable property is exempted from tax, the tax so

charged shall not exceed 15 per cent of the gross amount of

the dividends.



This paragraph shall not affect the taxation of the company

in respect of the profits out of which the dividends are

paid.



3. The term "dividends" as used in this Article means income

from shares or other rights, not being debt-claims,

participating in profits, as well as any other item which is

treated as income from shares by the taxation laws of the

State of which the company making the distribution is a

resident.



4. The provisions of paragraphs 1 and 2 shall not apply if

the beneficial owner of the dividends, being a resident of a

Contracting State, carries on business in the other

Contracting State of which the company paying the dividends

is a resident through a permanent establishment situated

therein and the holding in respect of which the dividends are

paid is effectively connected with such permanent

Re-establishment. In such case the provisions of Article 7 shall

apply.



5. Where a company which is a resident of a Contracting State

derives profits or income from the other Contracting State,

that other State may not impose any tax on the dividends paid

by the company, except insofar as such dividends are paid to

a resident of that other State or insofar as the holding in

respect of which the dividends are paid is effectively

connected with a permanent establishment situated in that

other State, nor subject the company's undistributed profits

to a tax on the company's undistributed profits, even if the

dividends paid or the undistributed profits consist wholly or

partly of profits or income arising in that other State.



6. No relief shall be available under this Article if it was

the main purpose or one of the main purposes of any person

concerned with the creation or assignment of the shares or

other rights in respect of which the dividend is paid to take

advantage of this Article by means of that creation or

assignment.



Article 11



Interest



1. Interest arising in a Contracting State and beneficially

owned by a resident of the other Contracting State shall be

taxable only in that other State.



2. The term "interest" as used in this Article means income

from debt-claims of every kind, whether or not secured by

mortgage and whether or not carrying a right to participate

in the debtor's profits, and in particular, income from

Government securities and income from bonds or debentures,

including premiums and prizes attaching to such securities,

bonds or debentures. Penalty charges for late payment shall

not be regarded as interest for the purpose of this Article.

The term shall not include any item which is treated as a

a dividend under the provisions of Article 10.



3. The provisions of paragraph 1 shall not apply if the

beneficial owner of the interest, being a resident of a

Contracting State, carries on business in the other

Contracting State in which the interest arises through a

permanent establishment situated therein and the debt-claim

in respect of which the interest is paid is effectively

connected with such permanent establishment. In such case the

the provisions of Article 7 shall apply.



4. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and

some other person, the amount of the interest paid exceeds,

for whatever reason, the amount which would have been agreed

upon by the payer and the beneficial owner in the absence of

such relationship, the provisions of this Article shall apply

only to the last-mentioned amount. In such case, the excess

part of the payments shall remain taxable according to the

the laws of each Contracting State, due regard being had to the

other provisions of this Convention.



5. No relief shall be available under this Article if it was

the main purpose or one of the main purposes of any person

concerned with the creation or assignment of the debt-claim

in respect of which the interest is paid to take advantage of

This Article by means of that creation or assignment.



Article 12



Royalties



1. Royalties arising in a Contracting State and beneficially

owned by a resident of the other Contracting State shall be

taxable only in that other State.



2. The term "royalties" as used in this Article means

payments of any kind received as a consideration for the use

of, or the right to use, any copyright of literary, artistic

or scientific work including cinematograph films and films or

tapes for radio or television broadcasting, any patent, trade

mark, design or model, plan, secret formula or process, or

for information (know-how) concerning industrial, commercial

or scientific experience.



3. The provisions of paragraph 1 shall not apply if the

beneficial owner of the royalties, being a resident of a

Contracting State, carries on business in the other

Contracting State in which the royalties arise through a

permanent establishment situated therein and the right or

property in respect of which the royalties are paid is

effectively connected with such permanent establishment. In

such case the provisions of Article 7 shall apply.



4. Where, by reason of a special relationship between the

payer and the beneficial owner or between both of them and

some other person, the amount of the royalties paid exceeds,

for whatever reason, the amount which would have been agreed

upon by the payer and the beneficial owner in the absence of

such relationship, the provisions of this Article shall apply

only to the last-mentioned amount. In such case, the excess

part of the payments shall remain taxable according to the

the laws of each Contracting State, due regard being had to the

other provisions of this Convention.



5. No relief shall be available under this Article if it was

the main purpose or one of the main purposes of any person

concerned with the creation or assignment of the rights in

respect of which the royalties are paid to take advantage of

This Article by means of that creation or assignment.



Article 13



Capital gains



1. Gains derived by a resident of a Contracting State from

the alienation of immovable property referred to in Article 6

and situated in the other Contracting State may be taxed in

that other State.



2. Gains derived by a resident of a Contracting State from

the alienation of shares, other than shares in which there is

substantial and regular trading on a Stock Exchange, or

status interests, deriving more than 50 per cent of their

value directly or indirectly from immovable property situated

in the other Contracting State may be taxed in that other

State.



3. Gains from the alienation of movable property forming part

of the business property of a permanent establishment which

an enterprise of a Contracting State has in the other

Contracting State, including such gains from the alienation

of such a permanent establishment (alone or with the whole

Enterprise), may be taxed in that other State.



4. Gains that an enterprise of a Contracting State that

operates ships or aircraft in international traffic derives

from the alienation of such ships or aircraft, or from

movable property pertaining to the operation of such ships or

aircraft, shall be taxable only in that Contracting State.



With respect to gains derived by the air transport consortium

Scandinavian Airlines System (SAS), the provisions of this

paragraph shall apply only to such part of the gains as

corresponds to the participation held in that consortium by

SAS Sweden AB, the Swedish partner of SAS.



5. Gains from the alienation of any property, other than that

referred to in paragraphs 1, 2, 3 and 4, shall be taxable

only in the Contracting State of which the alienator is a

resident.



6. Notwithstanding the provisions of paragraphs 5, gains from

the alienation of shares or other rights in a company, or of

interests in a partnership or trust derived by an individual

the who has been a resident of a Contracting State and who has


become a resident of the other Contracting State, may be

taxed in the first-mentioned State if the alienation of the

property occurs at any time during the next seven years

following the date on which the individual has ceased to be a

resident of the first-mentioned State. The gain so taxed

shall not include the gain, if any, that accrues during the

period during which the individual is or was a resident of

the other Contracting State.



Article 14



Income from employment



1. Subject to the provisions of Articles 15, 17 and 18,

salaries, wages and other similar remuneration derived by a

the resident of a Contracting State in respect of an employment

shall be taxable only in that State unless the employment is

exercised in the other Contracting State. If the employment

is so exercised, such remuneration as is derived therefrom

may be taxed in that other State.



2. Notwithstanding the provisions of paragraph 1,

remuneration derived by a resident of a Contracting State in

respect of an employment exercised in the other Contracting

State shall be taxable only in the first-mentioned State

If:



a) the recipient is present in the other State for a

period or periods not exceeding in the aggregate 183 days in

any twelve month period commencing or ending in the fiscal

year concerned; and



b) the remuneration is paid by, or on behalf of, an employer

the who is not a resident of the other State; and



c) the remuneration is not borne by a permanent establishment

which the employer has in the other State.



3. Notwithstanding the preceding provisions of this Article,

remuneration derived by a resident of a Contracting State in

respect of an employment exercised aboard a ship or aircraft

operated in international traffic (other than aboard a ship

or aircraft operated solely within the other Contracting

State) shall be taxable only in that State.



Article 15



Directors ' fees



Directors ' fees and other similar payments derived by a

the resident of a Contracting State in his capacity as a member

of the board of directors of a company which is a resident of

the other Contracting State may be taxed in that other

State.



Article 16



Artistes and sportsmen



1. Notwithstanding the provisions of Article 14, income

derived by a resident of a Contracting State as an

entertainer, such as a theatre, motion picture, radio or

television artiste, or a musician, or as a sportsman, from

his personal activities as such exercised in the other

Contracting State, may be taxed in that other State.



2. Where income in respect of personal activities exercised

by an entertainer or a sportsman in his capacity as such

accrues not to the entertainer or sportsman himself but to

another person, that income may, notwithstanding the

the provisions of Article 14, be taxed in the Contracting State

in which the activities of the entertainer or sportsman are

exercised.



Article 17



Pensions, annuities and similar payments



1. Pensions and other similar remuneration (including

annuities arising in a Contracting State), and disbursements

under the Social Security legislation of a Contracting State

may be taxed in that State.



2. The term "annuity" means a stated sum payable periodically

at stated times during life or during a specified or

ascertainable period of time under an obligation to make the

payments in return for adequate and full consideration in

money or money's worth.



Article 18



Government service



1. a Salaries, wages) and other similar remuneration, other

than a pension, paid by a Contracting State or a political

subdivision or a local authority thereof to an individual in

respect of services rendered to that State or subdivision or

authority shall be taxable only in that State.



b) However, such salaries, wages and other similar

remuneration shall be taxable only in the other Contracting

State if the services are rendered in that State and the

individual is a resident of that State who:



(i) is a national of that State; or



(ii) did not become a resident of that State solely for the

purpose of rendering the services;



and is subject to tax in that State on such salaries, wages

and other similar remuneration.



2. The provisions of Articles 14, 15 and 16 shall apply to

salaries, wages and other similar remuneration in respect of

services rendered in connection with a business carried on by

(a) the Contracting State or a political subdivision or a local

authority thereof.



Article 19



The student's



Payments which a student or business apprentice who is or

was immediately before visiting a Contracting State a

resident of the other Contracting State and who is present in

the first-mentioned State solely for the purpose of his

education or training receives for the purpose of his

maintenance, education or training shall not be taxed in that

State, provided that such payments arise from sources outside

that State.



Article 20



Other income



1. Items of income beneficially owned by a resident of a

Contracting State, wherever arising, not dealt with in the

foregoing Articles of this Convention shall be taxable only

in that State.



2. Notwithstanding the provisions of paragraph 1, where an

amount of income is paid to a resident of a Contracting State

out of income received by trustees or staff

representatives administering the estates of deceased persons

and those trustees or personal representatives are residents

of the other Contracting State, that amount shall be treated

as arising from the same sources, and in the same

proportions, as the income received by the trustees or

staff representatives out of which that amount is paid.



Any tax paid by the trustees or personal representatives in

respect of the income paid to the beneficiary shall be

treated as if it had been paid by the beneficiary.



3. The provisions of paragraph 1 shall not apply to income,

other than income from immovable property as defined in

paragraph 2 of Article 6, if the beneficial owner of such

income, being a resident of a Contracting State, carries on

business in the other Contracting State through a permanent

establishment situated therein and the right or property in

respect of which the income is paid is effectively connected

with such permanent establishment. In such case the

the provisions of Article 7 shall apply.



4. Where, by reason of a special relationship between the

resident referred to in paragraph 1 and some other person, or

between both of them and some third person, the amount of the

the income referred to in that paragraph exceeds the amount (if

any) which would have been agreed upon between them in the

absence of such a relationship, the provisions of this

Article shall apply only to the last-mentioned amount. In

such case, the excess part of the income shall remain taxable

According to the laws of each Contracting State, due regard

being had to the other applicable provisions of this

Convention.



5. No relief shall be available under this Article if it was

the main purpose or one of the main purposes of any person

concerned with the creation or assignment of the rights in

respect of which the income is paid to take advantage of this

Article by means of that creation or assignment.



Article 21



Elimination of double taxation



1. In the case of Sweden, double taxation shall be avoided

as follows:



a) Where a resident of Sweden derives income which under the

the laws of the United Kingdom and in accordance with the

the provisions of this Convention may be taxed in the United

Kingdom, Sweden shall allow, subject to the provisions of the

the laws of Sweden concerning credit for foreign tax (as they may

be amended from time to time without changing the general

principle hereof)-as a deduction from the tax on such income,

an amount equal to the United Kingdom tax paid in respect of

such income.



b) Where a resident of Sweden derives income which, in

accordance with the provisions of this Convention, shall be

taxable only in the United Kingdom, Sweden may, when

determining the graduated rate of Swedish tax, take into

account the income which shall be taxable only in the United

Kingdom.



(c) Notwithstanding the provisions of subparagraph) (a)) of this

paragraph, dividends paid by a company which is a resident of

the United Kingdom to a company which is a resident of Sweden

shall be exempt from Swedish tax according to the provisions

of Swedish law governing the exemption of tax on dividends

paid to Swedish companies by companies abroad.



2. Subject to the provisions of the law of the United Kingdom

regarding the allowance as a credit against United Kingdom

tax of tax payable in a territory outside the United Kingdom

or, as the case may be, regarding the exemption from United

Kingdom tax of a dividend arising in a territory outside the

United Kingdom or of the profits of a permanent establishment

situated in a territory outside the United Kingdom (which

shall not affect the general principle hereof):



Swedish tax payable under (a)) the laws of Sweden and in

accordance with this Convention, whether directly or by

deduction, on profits, income or chargeable gains from

sources within Canada (excluding in the case of a dividend

tax payable in respect of the profits out of which the

dividend is paid) shall be allowed as a credit against any

United Kingdom tax computed by reference to the same profits,

income or chargeable gains by reference to which the Swedish

tax is computed;



(b)) a dividend which is paid by a company which is a resident

of Sweden to a company which is a resident of the United

Kingdom shall be exempted from United Kingdom tax when the

exemption is applicable and the conditions for exemption

under the law of the United Kingdom are met;



(c)), the profits of a permanent establishment in Sweden of a

company which is a resident of the United Kingdom shall be


exempted from United Kingdom tax when the exemption is

applicable and the conditions for exemption under the law of

the United Kingdom are met;



d) in the case of a dividend not exempted from tax under

subparagraph (b)) above which is paid by a company which is a

resident of Sweden to a company which is a resident of the

United Kingdom and which controls directly or indirectly at

least 10 per cent of the voting power in the company paying

the dividend, the credit mentioned in subparagraph (a)) above

shall also take into account the Swedish tax payable by the

company in respect of its profits out of which such dividend

is paid.



3. For the purposes of paragraphs 1 and 2, profits, income

and gains owned by a resident of a Contracting State which

may be taxed in the other Contracting State in accordance

with this Convention shall be deemed to arise from sources in

that other State.



4. Where a resident of a Contracting State derives gains

which may be taxed in the other Contracting State under the

the provisions of paragraph 6 of Article 13, and those gains are

in respect of:



a) shares or interests status referred to in paragraph 2

of Article 13, and the immovable property in question is

situated in the first-mentioned Contracting State, or



b) shares referred to in paragraph 7 of Article 26, and the

the rights in question are to assets to be produced by the

the exploration or exploitation of the sea-bed and subsoil and

their natural resources situated in the first-mentioned

Contracting State



that other Contracting State shall allow, under the

the provisions of paragraphs 1 or 2, as the case may be, (a)

deduction of, or a credit for the tax paid on that gain in

the first-mentioned Contracting State.



Article 22



Non-discrimination



1. Nationals of a Contracting State shall not be subjected

in the other Contracting State to any taxation or any

requirement connected therewith which is other or more

burdensome than the taxation and connected requirements to

which nationals of that other State in the same

circumstances, in particular with respect to residence, are

or may be subjected.



2. The taxation on a permanent establishment which an

Enterprise of a Contracting State has in the other

Contracting State shall not be less favourably levied in that

other State than the taxation levied on enterprises of that

other State carrying on the same activities.



3. Except where the provisions of paragraph 1 of Article 9,

paragraph 4 or 5 of Article 11, paragraph 4 or 5 of Article

12, or paragraph 4 or 5 of Article 20 apply, interest,

royalties and other disbursements paid by an enterprise of a

Contracting State to a resident of the other Contracting

State shall, for the purpose of determining the taxable

profits of such enterprise, be deductible under the same

conditions as if they had been paid to a resident of the

the first-mentioned State.



4. Enterprises of a Contracting State, the capital of which

is wholly or partly owned or controlled, directly or

indirectly, by one or more residents of the other Contracting

State, shall not be subjected in the first-mentioned State to

any taxation or any requirement connected therewith which is

other or more burdensome than the taxation and connected

requirements to which other similar enterprises of the

the first-mentioned State are or may be subjected.



5. Nothing contained in this Article shall be construed as

obliging either Contracting State to grant to individuals not

resident in that State any of the personal allowances,

reliefs and reductions for tax purposes which are granted to

individuals so resident or to its nationals.



Article 23



Mutual agreement procedure



1. Where a person considers that the actions of one or both

of the Contracting States result or will result for him in

taxation not in accordance with the provisions of this

Convention, he may, irrespective of the remedies provided by

the domestic law of those States, present his case to the

competent authority of the Contracting State of which he is a

resident or, if his case comes under paragraph 1 of Article

22, to that of the Contracting State of which he is a

National. The case must be presented within three years from

the first notification of the action resulting in taxation

not in accordance with the provisions of the Convention.



2. The competent authority shall endeavour, if the objection

appears to it to be justified and if it is not itself able to

arrive at a satisfactory solution, to resolve the case by

mutual agreement with the competent authority of the other

Contracting State, with a view to the avoidance of taxation

which is not in accordance with the Convention. Any agreement

reached shall be implemented notwithstanding any time limits

in the domestic law of the Contracting States.



3. The competent authorities of the Contracting States shall

endeavour to resolve by mutual agreement any difficulties or

doubts arising as to the interpretation or application of the

Convention. They may also consult together for the

Elimination of double taxation in cases not provided for in

the Convention.



4. The competent authorities of the Contracting States may

communicate with each other directly for the purpose of

reaching an agreement in the sense of the preceding

paragraphs.



5. Where,



(a) in paragraph 1, a) person has presented a case to the

competent authority of a Contracting State on the basis that

the actions of one or both of the Contracting States have

resulted for that person in taxation not in accordance with

the provisions of this Convention, and



(b)), the competent authorities are unable to reach an agreement

to resolve that case pursuant to paragraph 2 within three

years from the presentation of the case to the competent

authority of the other Contracting State,



any unresolved issues arising from the case shall be

submitted to arbitration if the person so requests. These

unresolved issues shall not, however, be submitted to

arbitration if a decision on these issues has already been

rendered by a court or administrative tribunal of either

State. Unless a person directly affected by the case does not

accept the mutual agreement that implements the arbitration

decision, that decision shall be binding on both Contracting

States and shall be implemented notwithstanding any time

limits in the domestic laws of these States. The competent

authorities of the Contracting States may by mutual agreement

settle the mode of application of this paragraph.



6. a) The provisions of paragraph 5 shall not apply to cases

falling within paragraph 3 of Article 4 or to issues

concerning the attribution of capital to a permanent

Re-establishment under Article 7.



(b) Notwithstanding the provisions of paragraph) 5, a case

shall not be submitted to arbitration if the competent

authorities of both Contracting States have agreed that the

case is not suitable for resolution through arbitration.



Article 24



Exchange of information



1. The competent authorities of the Contracting States shall

Exchange such information as is foreseeably relevant for

carrying out the provisions of this Convention or to the

Administration or enforcement of the domestic laws concerning

taxes of every kind and description imposed on behalf of the

Contracting States, or of their political subdivisions or

local authorities, insofar as the taxation thereunder is not

contrary to the Convention. The exchange of information is

not restricted by Articles 1 and 2.



2. Any information received under paragraph 1 by a

Contracting State shall be treated as secret in the same

manner as information obtained under the domestic laws of

that State and shall be disclosed only to persons or

authorities (including courts and administrative bodies)

concerned with the assessment or collection of, the

enforcement or prosecution in respect of, the determination

of appeals in relation to the taxes referred to in paragraph

1, or the oversight of the above. Such persons or authorities

shall use the information only for such purposes. They may

disclose the information in public court proceedings or in

judicial decisions. Notwithstanding the foregoing,

information received by a Contracting State may be used for

other purposes when such information may be used for such

other purposes under the laws of both States and the

competent authority of the supplying State authorises such

use.



3. In no case shall the provisions of paragraphs 1 and 2 be

construed so as to impose on a Contracting State the

bond:



(a)) to carry out administrative measures at variance with the

laws and administrative practice of that or of the other

Contracting State;



b) to supply information which is not obtainable under the

laws or in the normal course of the administration of that or

of the other Contracting State;



c) to supply information which would disclose any trade,

business, industrial, commercial or professional secret or

trade process, or information the disclosure of which would

be contrary to public policy (ordre public).



4. If information is requested by a Contracting State in

accordance with this Article, the other Contracting State

shall use its information gathering measures to obtain the

requested information, even though that other State may not

need such information for its own tax purposes. The

obligation contained in the preceding sentence is subject to

the limitations of paragraph 3 but in no case shall such

limitations be construed to permit a Contracting State to

decline to supply information solely because it has no

domestic interest in such information.



5. In no case shall the provisions of paragraph 3 be

construed to permit a Contracting State to decline to supply

information solely because the information is held by a bank,


other financial institution, nominee or person acting in an

Agency or a fiduciary capacity or because it relates to

ownership interests in a person.



Article 25



Members of diplomatic missions and consular posts



Nothing in this Convention shall affect the fiscal

privileges of members of diplomatic missions or consular

posts under the general rules of international law or under the

the provisions of special agreements.



Article 26



Miscellaneous provisions relating to offshore activities



1. The provisions of this Article shall apply

Notwithstanding any other provision of this Convention where

the activities (in this Article "relevant activities") are

carried on offshore in connection with the exploration or

exploitation of the sea-bed and subsoil and their natural

resources situated in a Contracting State.



2. An enterprise of a Contracting State which carries on

relevant activities in the other Contracting State shall,

subject to paragraphs 3 and 4 of this Article, be deemed to

be carrying on business in that other Contracting State

through a permanent establishment situated therein.



3. Relevant activities which are carried on by an enterprise

of a Contracting State in the other Contracting State for a

period or periods not exceeding in the aggregate 30 days in

any 12-month period shall not constitute the carrying on of

business through a permanent establishment situated therein.

For the purposes of this paragraph:



(a)) where an enterprise of a Contracting State carrying on

relevant activities in the other Contracting State is

associated with another enterprise carrying on substantially

similar relevant activities there, the former enterprise

shall be deemed to be carrying on all such activities of the

latter enterprise, except to the extent that those activities

are carried on at the same time as its own activities;



b) an enterprise shall be regarded as associated with another

Enterprise if one participates directly or indirectly in the

management, control or capital of the other or if the same

persons participate directly or indirectly in the management,

control or capital of both enterprises.



4. Profits derived by an enterprise of a Contracting State

from the transportation of supplies or personnel by a ship or

aircraft to a location where the relevant activities are being

carried on, or from the operation of tugboats or anchor

action vessels in connection with such activities, shall be

taxable only in that Contracting State.



5. (a) Subject to subparagraph (b))) of this paragraph, salaries,

wages and similar remuneration derived by a resident of a

Contracting State in respect of an employment connected with

relevant activities in the other Contracting State may, to

the extent that the duties are performed offshore in that

other Contracting State, be taxed in that other Contracting

State.



(b) wages and Salaries), similar remuneration derived by a

the resident of a Contracting State in respect of an employment

exercised aboard a ship or aircraft engaged in the

the transportation of supplies or personnel to a location where

relevant activities are being carried on in a Contracting

State, or in respect of any employment exercised aboard (a)

tugboat or anchor handling vessel in connection with such

activities, shall be taxable only in the State of which the

individual is a resident.



6. Gains derived by an enterprise of a Contracting State that

operates:



a) ships or aircraft for the transportation of supplies or

personnel to a location where the relevant activities are being

carried on in a Contracting State, or



b) tugboats or anchor handling vessels operated in connection

with such activities from the alienation of such ships,

aircraft, tugboats or anchorhandling vessels shall be taxable

only in that Contracting State.



7. Gains derived by a resident of a Contracting State from

the alienation of rights to assets to be produced by the

the exploration or exploitation of the sea-bed and subsoil and

their natural resources situated in the other Contracting

State, including rights to interests in or to the benefit of

such assets, or from the alienation of shares deriving their

value or the greater part of their value directly or

indirectly from such rights, may be taxed in that other

Contracting State.



Article 27



Preferential regimes



Notwithstanding any other provisions of this Convention,

the where



(a)) a company that is a resident of a Contracting State

derives its income primarily from other States



(i) from shipping and financial activities, or



(ii) from being the headquarters or co-ordination centre for,

or from being an entity providing administrative services or

other support to, a group of companies which carry on

business primarily in other States; and



b) under a preferential regime, such income bears a

significantly lower tax than income from similar activities

carried out within that State or than income from being the

Headquarters, co-ordination centre or similar entity

providing administrative services or other support to a group

of companies which carry on business in that State, as the

case may be,



any provisions of this Convention conferring an exemption or

(a) reduction of taxes shall not apply to the income of such

company and paragraph 2 of Article 10 and Article 21 shall

Note apply to the dividends paid by such company.



Article 28



Miscellaneous



Where under any provision of this Convention, income or

capital gains are relieved from tax in a Contracting State

and, under the laws in force in the other Contracting State,

an individual, in respect of that income or that capital gain

is subject to tax by reference to the amount thereof which is

remitted to or received in that other Contracting State and

not by reference to the full amount thereof, then the relief

to be allowed under the Convention in the first-mentioned

Contracting State shall apply only to so much of the income

or capital gain as is taxed in that other Contracting

State.



Article 29



Entry into force



1. Each of the Contracting States shall notify the other in

writing, through diplomatic channels, of the completion of

the procedures required by its law for the entry into force

of this Convention.



2. The Convention shall enter into force on the thirtieth day

After the receipt of the later of these notifications and

shall thereupon have effect:



a) in Sweden:



(i) in respect of taxes withheld at source, for amounts paid

or credited on or after 1st January of the year next

following the date on which the Convention enters into

force;



(ii) in respect of other taxes on income, for taxes

chargeable for any tax year beginning on or after 1st January

of the year next following the date on which the Convention

enters into force; and



(b)) in the United Kingdom:



(i) in respect of taxes withheld at source, for amounts paid

or credited on or after 1st January of the year next

following the date on which the Convention enters into

force;



(ii) in respect of income tax and capital gains tax, for any

year of assessment beginning on or after 6th April next

following the date on which this Convention enters into

force;



(iii) in respect of corporation tax, for any financial year

beginning on or after 1st April next following the date on

which this Convention enters into force.



3. Notwithstanding the provisions of paragraph 1, the

the provisions of Article 23 (Mutual agreement procedure) and

Article 24 (Exchange of information) shall have effect from

the date of entry into force of this Convention, without

regard to the taxable period to which the matter relates.

However, in no case may be submitted for arbitration under the

the provisions of paragraph 5 of Article 23 (Mutual agreement

procedure) earlier than three years after the date on which

the Convention enters into force.



4. The Convention between the Government of the Kingdom of

Sweden and the Government of the United Kingdom of Great

Britain and Northern Ireland for the avoidance of double

taxation and the prevention of fiscal evasion with respect to

taxes on income and capital gains, signed at Stockholm on

30th August 1983 ("the prior Convention") shall cease to

have effect in respect of any tax with effect from the date

upon which this Convention has effect in respect of that tax

in accordance with the provisions of paragraph 1 of this

Article and shall terminate on the last such date.



5. Notwithstanding the provisions of paragraphs 2 and 4 and

the provisions of Article 17, where, immediately before the

entry into force of this Convention, an individual was in

receipt of payments falling within Article 18 or paragraph 2

of Article 19 of the prior Convention, that individual may

make an election that the provisions of those Articles, and

Note the provisions of Article 17 of this Convention, shall

continue to apply to those payments. That election shall have

effect for the year in which it is made and for subsequent

years unless revoked by the individual. Where an election

has been so revoked, no further election under this paragraph

may be made.



Article 30



Termination



This Convention shall remain in force until terminated by a

Contracting State. Either Contracting State may terminate the

The Convention, through diplomatic channels, by giving written

notice of termination at least six months before the end of

any calendar year. In such case, the Convention shall cease

to have effect



a) in Sweden:



(i) in respect of taxes withheld at source, for amounts paid

or credited on or after 1st January of the year next

following the end of the six month period;



(ii) in respect of other taxes on income, for taxes

chargeable for any tax year beginning on or after the first

day of January of the year next following the end of the six

month period; and



(b)) in the United Kingdom:




(i) in respect of taxes withheld at source, for amounts paid

or credited on or after 1st January of the year next

following the end of the six month period;



(ii) in respect of income tax and capital gains tax, for any

year of assessment beginning on or after 6th April next

following the date on which the notice is given;



(iii) in respect of corporation tax, for any financial year

beginning on or after 1st April next following the date on

which the notice is given.



In witness whereof the undersigned, being duly authorised

thereto, have signed this Convention.



Done in duplicate at Stockholm this 26th day of March 2015 in

the English language.



For the Government of the Kingdom of Sweden



Linda Haggren



For the Government of the United Kingdom of Great Britain and

Northern Ireland



Paul Johnston



(Translation)



Agreement between the Kingdom of Sweden and the United Kingdom of

United Kingdom and Northern Ireland for the avoidance of

double taxation and the prevention of fiscal evasion with respect to

taxes on income and on capital gains



The Government of the Kingdom of Sweden and the United Kingdom of

United Kingdom and Northern Ireland,



Desiring to conclude an agreement for the avoidance of double taxation

and the prevention of fiscal evasion with respect to taxes on

income and on capital,



have agreed as follows:



Article 1



Persons to whom the agreement applies



1. This agreement shall apply to persons who are domiciled in a

Contracting State or in both Contracting States.



2. for the purposes of this agreement, the income or profits which

is acquired by, or by a person whose income or profit

under the legislation of either Contracting State is

subject to shareholder taxation are considered acquired by a person

a resident of one of the Contracting States to the extent

as the income or profits, according to the tax laws of

This State, shall be treated as income or profits of a person

a resident of the State in question. The provisions of this paragraph

does not limit in any way a Contracting State to

taxing income or profits acquired by resident

in this State.



Article 2



Taxes covered by the agreement



1. this Agreement shall apply to taxes on income and on

the capital gain in respect of a Contracting State, its

political underavdelningars or local authorities

behalf, independent of the way in which taxes are levied.



2. taxes on income and on capital gains, of course, all

taxes levied on income in its entirety or in parts of

income, including taxes on profit due to

transfer of movable or immovable property, as well as taxes on

capital appreciation.



3. The taxes to which this Agreement shall apply are:



a) in Sweden:



1) state income tax,



2) withholding tax,



3) the Special income tax for non-residents,



4) the Special income tax for non-residents

artists and others, and



5) the municipal income tax,



(referred to below as "Swedish tax");



(b)) in the United Kingdom of United Kingdom and Northern Ireland:



1) income tax



2) corporate tax rate, and



3) capital gains tax,



(referred to below as the "British tax").



4. the agreement also applies to the taxes of the same or

mainly similar kind, as after the signing of the agreement

charged alongside or in place of the taxes referred

in paragraph 3. The competent authorities of the Contracting

States shall notify each other of the essential changes that

made in their tax legislation.



Article 3



General definitions



1. Unless the context gives rise to different, have at

the application of this agreement the following expressions below specified

importance:



a) "Sweden" means the Kingdom of Sweden and, when the expression

used in geographical sense, includes the Swedish

territory, the territorial sea of Sweden and other maritime areas

over which Sweden in accordance with the rules of international law

sovereignty or jurisdiction,



b) "United Kingdom" refers to the United Kingdom and

Northern Ireland but, when the expression is used in a geographical

importance, including United Kingdom and Northern Ireland

territory and territorial sea, and any area located

outside the territorial sea of the United Kingdom and Northern Ireland

the United Kingdom and Northern Ireland in accordance with the

its legislation and the rules of international law exercises sovereign

rights or jurisdiction;



(c)) "a Contracting State" and "the other Contracting

the State "refers to Sweden or the United Kingdom, depending

on the context,



d) "person" includes natural persons, companies and other

Association,



e) "company" means any legal person or any other that at

taxation is treated as a legal person,



f) "company" means the exercise of any form of movement,



g) "enterprise of a Contracting State" and "enterprise of the

other Contracting State "mean business conducted by a

resident of a Contracting State, and

business carried on by a resident of the other

Contracting State,



h) "international transport" means transport by ship or

aircraft, except when the ship or aircraft is used

exclusively between places in a Contracting State by an

company that is not a business in this State,



in) "competent authority" means:



1) in Sweden, the Minister of finance or his authorised representative

or authority to whom be entrusted to be competent

authority for the purposes of this agreement,



2) in the United Kingdom, "the Commissioners for Her

Majesty's Revenue and Customs "or their authorized

agents,



j) "citizen", refers to:



1) in Sweden, the natural person who is a Swedish citizen and

legal person, partnership or other association

formed under current Swedish law,



2) in the United Kingdom, British citizens or

British person who does not hold the nationality of any other

State, or other territory, in the Commonwealth, under

the condition that the person concerned has the right to reside in the

United Kingdom, as well as legal person, partnership

or other association constituted under the applicable

British law,



k) "movement" includes the exercise of a liberal profession, and other

independent operations.



2. Where a Contracting State applies the contract at any

time is deemed, unless the context shall give rise to different,

any expression that is not defined in this agreement have the meanings

that statement has at that time under the State's

legislation in respect of such taxes to which the agreement

applied, and the significance of the phrase under the

the applicable tax laws of that State primacy

in front of the importance of the expression given in other legislation in

This state.



Article 4



Resident



1. for the purposes of this agreement, the expression "person

resident in one Contracting State "person under

the laws of that State, is liable to tax there because of

domicile, residence, place of management, place of

formation, or other similar circumstances involving

also the State, its bodies governed by public law, or

institutions, political subdivisions or local

authorities. This expression, however, does not include a person

who is liable to tax in that State only for income or

capital gains from sources in that State.



2. where by reason of the provisions of paragraph 1 an individual is

a resident of both Contracting States, is determined his residence

in the following ways:



(a)) he is considered to be resident only of the State in which he has a

residence permanently at his disposal. If he

has such a property in both States, he shall be deemed to be a resident

only of the State with which his personal and economic

relations are strongest (Centre of life interests),



(b)) if it cannot be settled in the State he has Center for

their living interests or if he is not in any State

has a permanent home available to him;

He is considered to be a resident only of the State in which he habitually

vistas,



(c)) if he usually resides in both States, or if he

not reside permanently in any of them, he shall be deemed to have

resident only of the State in which he is a national,



d) if he is a national of both States or if he is not

nationals of any of them, the competent authorities of the

Contracting States may settle the question by mutual

agreement.



3. where by reason of the provisions of paragraph 1 a person other than the

an individual is a resident of both Contracting States, the

the competent authorities of the Contracting States,

mutual agreement, seek to determine the Contracting

State the person is deemed to be domiciled in the application of

This agreement. In the absence of a mutual agreement

between the competent authorities of the Contracting States

the person is not considered to be a resident of either Contracting

State in order to seek other benefits under this agreement than

those resulting from the application of articles 21, 22 and 23.



Article 5



Permanent establishment



1. for the purposes of this agreement the term "fixed

establishment means a fixed place of business,

from which a business wholly or partly

is conducted.



2. The term "permanent establishment" includes especially:



a) place of business management,



b) branch,



c) offices,



d) factory,



e) workshop, and



f) mine, an oil or gas well, a quarry or any other place

for the extraction of natural resources.



3. Place for building, construction, Assembly or

installation activities or business that consists of

monitoring in connection therewith constitutes a permanent establishment


only if the operation lasts longer than twelve months.



4. Notwithstanding the preceding provisions of this article

considered the expression "permanent establishment" shall not include:



(a)) the use of facilities solely for storage,

exhibition or disclosure of company-owned goods,



(b) holding of a company belonging) inventories

exclusively for storage, exhibition or distribution,



(c) holding of a company belonging) inventories

exclusively for working or processing by another

corporate merchandise,



d) holding of fixed place of business

exclusively for the purchase of goods or obtaining

information of the company,



e) holding of fixed place of business

exclusively for the enterprise carrying on other activities of the

preparatory or auxiliary nature,



f) an installation project as a company in a

Contracting State, carries on in the other Contracting

the State in connection with the supply of machinery or equipment

manufactured by the company,



g) holding of fixed place of business

exclusively for any combination of activities mentioned in

a) to f) above, provided that all the activities

carried out from the permanent location of the

business as a result of this combination is the

preparatory or auxiliary character.



5. If a person who is not an independent representative

at which point 6 applies – and works for a company and

in a Contracting State and which are regularly using

authority to conclude contracts in the name of the company, considered this

– Notwithstanding the provisions of paragraphs 1 and 2 to

to have a permanent establishment in that State in respect of each activity

that person is driving for the company. However, this does not apply, if

the activities of such person are limited to the

referred to in paragraph 4 and which, if it was done from a

fixed place of business, would not make

This fixed place of business to the firm

establishment, in accordance with the provisions of that paragraph.



6. the Company is not considered to have a permanent establishment in a Contracting

State only on the basis that the company conducts

business in that State through the intermediary of brokers,

Commissioner, or other independent agent, in

in doing so, provided that such person is engaged in his customary

business operations.



7. the fact that a company resident in a

Contracting State controls or is controlled by a

a company resident in the other Contracting State or in a

companies doing business in the other State

(either from a permanent establishment or otherwise),

not in itself constitute either company a permanent establishment of the

the other.



Article 6



Income from immovable property



1. income, as a person resident in one Contracting State

acquires immovable property (including income from

agriculture or forestry) situated in the other Contracting

the State, may be taxed in that other State.



2. The term "immovable property" has the same meaning as the expression

under the laws of the Contracting State in which the

the property is situated. The term includes, however, always

accessory to immovable property, the living and the dead furniture in

Agriculture and forestry, rights to which the provisions of

private law on immovable property apply, buildings,

tenancies of immovable property and rights to changing

or fixed remuneration for the use of, or the right to

use mineral occurrence, source or another natural resource.

Ships, boats and aircraft is not considered to be real property.



3. the provisions of paragraph 1 shall apply to income

acquired by immediately use, through rental or

other uses of real property.



4. the provisions of paragraphs 1 and 3 apply also to

income from immovable property belonging to the company.



Article 7



Income from operating



1. the Income of an enterprise of a Contracting State

acquire, shall be taxable only in that State unless the

the company carries on business in the other Contracting State

from permanent establishment situated there. If the company conducts

operating on just now, get income attributable

to the permanent establishment in accordance with the provisions of

paragraph 2 shall be taxed in the other State.



2. For the purposes of this article and article 21, the

income in each Contracting State is attributable to

the permanent establishment referred to in paragraph 1 shall be the income

as it can be assumed that the establishment would have acquired,

particularly with respect to the establishment, has dealings with

other parts of the company, if it had been a stand-alone

companies that operated out of the same or a similar kind

under the same or similar conditions, with regard to the

functions performed, assets used and risks

the company has taken through the permanent establishment and by

other parts of the company.



3. In cases where one Contracting State, in accordance with paragraph 2,

Adjusts the income is attributable to a fixed

establishment of a company resident in one of the

Contracting States and therefore taxes the company for

income that has been taxed in the other State, such

other State, to the extent that is necessary to

avoid double taxation of such income, implement

proper adjustment if it agrees with the adjustment

made by the former State. If the other Contracting

the State does not agree, the Contracting States shall seek

eliminate any double taxation as a result of this

by mutual agreement.



4. Included in income by operating income or capital gains which

treated specially in other articles of this agreement, concerned

the provisions of these articles, not to the provisions of

This article.



Article 8



Sea and air transport



1. income acquired by the company in a Contracting State

through the use of ships or aircraft in international

traffic shall be taxable only in that State.



2. the provisions of paragraph 1 shall apply to income

acquired by the air transport Consortium Scandinavian Airlines System

(SAS) but only in respect of that part of the income that

corresponds to the percentage of the Consortium held by SAS Sweden

AB, the Swedish partner of SAS.



3. For the purposes of this article are included in the income

acquired by the enterprises of a Contracting State through the

the use of ships or aircraft in international

traffic,



a) income acquired by lease of unmanned ship

or aircraft, and



b) income is acquired by use, maintenance or

rental of containers (including trailers and other

equipment for the transport of containers) used for the

the transport of goods or merchandise,



provided that such rental or such

the use, maintenance or rental is of secondary

significance in relation to the company's use of ship

or aircraft in international traffic.



4. the provisions of paragraph 1 shall also apply to income

acquired through participation in a pool, a joint business

or an international operating agency.



Article 9



Companies with associated enterprises



1. In cases where:



a) an enterprise of a Contracting State, either directly or indirectly

participate in the management or control of an undertaking within the

other Contracting State or own part in this business

capital, or



(b)) the same person participates directly or indirectly in the management,

or the control of a company of a Contracting

State as an enterprise of the other Contracting State, or

owns part of both of these corporate capital, observed the following.



If between businesses in terms of trade relations or

financial relations agreed upon or prescribed conditions,

which differ from those which would have been agreed between the

independent companies, receives all the income, that without such

the conditions would have been one company but on

because of the conditions in question did not come about this company,

included in this corporate income and are taxed in

accordingly.



2. In cases where one Contracting State in the income of a

companies in this State include – and accordingly

taxes – income, for which a company in the other

Contracting State subject to tax in that other State, as well as the

thus included the income is such as would have been

companies in the first State on the terms and conditions agreed

between the enterprises had been those which would have been agreed

between independent enterprises, then that other State

implement the proper adjustment of the amount of the tax

charged to income. In compliance with such other adjustment

provisions of this agreement and the competent authorities of the

Contracting States are in talks with each other when necessary.



Article 10



Dividend



1. Dividends paid by a company resident in one Contracting State

to a resident of the other Contracting State,

be taxed in that other State.



2. Dividends paid by a company resident in one Contracting State

may be taxed in that State, in accordance with

the laws of that State, but if the beneficial owner of

the dividend is a resident of the other

a Contracting State may not exceed 5% of

the gross amount of the dividends. Such dividend shall however

be exempt from taxation in the Member State in which the company

paying the dividends is a resident, if the person entitled to

the payout is a company which controls, directly or

indirectly, at least 10% of the company

number of votes.




As regards dividends paid from income (including

profit) directly or indirectly acquired from such fixed

property referred to in article 6 of a commitment to collective

investment which annually awards the majority of its

income and whose income from such immovable property is

exemptions from taxation shall – notwithstanding the preceding

provisions of this paragraph, the tax shall not exceed 15

per cent of the gross amount of the dividends.



This paragraph does not affect the company's taxation of the profits of

which the dividends are paid.



3. The term "dividends" is understood in this article income

of shares or other rights, not being debt-claims,

with the right to share in profits, as well as income from other

rights in companies under the law of the State in which

the company making the distribution is a resident for tax purposes are treated

in the same way as income from shares.



4. the provisions of paragraphs 1 and 2 do not apply, if the

who is entitled to the dividends is a resident of a Contracting

State and carries on business in the other Contracting State,

which the company paying the dividends is a resident, from where

permanent establishment situated, and the proportion due to the

dividend paid owns actual relation to the Permanent

establishment. In such cases, apply the provisions of

Article 7.



5. If the company resident in one Contracting State acquires

income from the other Contracting State, that other

State does not tax dividends paid by the company, except to the

so far as the dividend is paid to a resident of the other

State or insofar as the percentage due to the dividend payment

paid owns truly connected with a permanent establishment in this

other State, nor on the company's undistributed profits to

out a tax that is paid on the company's undistributed profits, even

If the dividend or the undistributed profits wholly or

partially consists of income arising in that other State.



6. Relief under this article shall not be obtained if the

main purpose or one of the main objectives, in

any person who has influence over the creation or

the placement of the shares or other rights, due

which the dividends are paid, is to obtain the benefit of this

Article by such a creation or placement.



Article 11



Interest rate



1. interest, stemming from a Contracting State, and as a

a resident of the other Contracting State has the right

to, shall be taxable only in that other State.



2. The term "interest" for the purposes of this article the income of

each kind of claim secured by either the

mortgage on immovable property or not, and whether it involves

right to share in the debtor's profits or not. The expression

relate in particular to income from securities issued by State

and income from bonds or debentures, including

premiums and benefits pertaining to such

securities, bonds or debentures; Penalty of

because of late payment is not considered as interest in applying

of this article. The term does not include such income

that is treated as a dividend under the provisions of article

10.



3. the provisions of paragraph 1 shall not apply if the

the right to interest is resident in a Contracting State and

carries on business in the other Contracting State, from

What interest rate are derived, from where the permanent establishment situated, as well as

the claim in respect of which the interest is paid possesses genuine link

with the permanent establishment. In such a case be applied

the provisions of article 7.



4. where by reason of a special relationship between the payer

and the beneficial owner of the interest or between both of them and

other person the amount of the interest, having regard to the claim for

the interest is paid, exceeds the amount which would be

agreed between the payer and the beneficial owner of the interest

If such links do not exist, the

the provisions of this article only on the latter amount. In

such cases are taxable surplus amount referred to in

the law of each Contracting State with

observance of the other provisions of this agreement.



5. Relief under this article shall not be obtained if the

main purpose or one of the main objectives, in

any person who has influence over the creation or

the location of the claim on the basis of which the interest is paid,

is to obtain the benefit of this article, such

creation or placement.



Article 12



Royalty



1. Royalty, as derived from a Contracting State and which

a resident of the other Contracting State has

right, shall be taxable only in that other State.



2. The term "royalties" in this article each

kind of payment that is received as compensation for the use

by or for the right to use copyright to literary,

artistic or scientific work, including

cinema films and films or tapes for radio or

television broadcasting, any patent, trade mark, design or

model, plan, secret formula or secret

manufacturing process, or for information (know-how) concerning

experience knowledge of industrial, commercial or scientific

nature.



3. the provisions of paragraph 1 shall not apply if the

entitled to the royalty is a resident of a Contracting State, and

carries on business in the other Contracting State, from

the royalties derived from the permanent establishment situated there,

and the right or property in respect of which the royalty

paid owns truly connected with the permanent establishment. In

in such cases the provisions of article 7.



4. where by reason of a special relationship between the payer

and the person entitled to the royalties or between both of them and

other person the amount of the royalties, having regard to the use,

the right or the enlightenment for which the royalty

paid, exceeds the amount which would have been agreed between

the payer and the beneficial owner of royalties if such

relations do not exist, the provisions of this

article only at the latter amount. In such a case be taxed

excess amounts in accordance with the legislation of each

Contracting State in compliance with the other provisions

in this agreement.



5. Relief under this article shall not be obtained if the

main purpose or one of the main objectives, in

any person who has influence over the creation or

location of rights on the basis of which the royalty

paid, is to obtain the benefit of this article, such

creation or placement.



Article 13



Capital gain



1. Profit, as a person resident in one Contracting State

acquires from the alienation of such immovable property

referred to in article 6 and situated in the other

Contracting State, may be taxed in that other State.



2. Profit, as a person resident in one Contracting State

acquires from the alienation of shares or similar

rights not in substantial basis and regularly

dealt in on a stock exchange, whose value to more than 50 per cent,

directly or indirectly attributable to real property which is

situated in the other Contracting State, may be taxed in the

that other State.



3. Gains from the alienation of movable property forming part

of the operating assets of a permanent establishment which an enterprise

of a Contracting State has in the other Contracting

the State, may be taxed in that other State. The same applies

gains from the alienation of such a permanent establishment (for

alone or with the whole enterprise).



4. Profit, which is being acquired by a company in Contracting State

acquires from the alienation of ships or aircraft

used in international traffic, or movable property which is

attributable to the use of such ship or aircraft;

be taxable only in that Contracting State.



The provisions of this paragraph shall apply in respect of profits

acquired by the air transport Consortium Scandinavian Airlines System

(SAS), but only in respect of the part of the profits as corresponds to the

the share in the Consortium held by SAS Sweden AB, the

Swedish partner of SAS.



5. Gains from the alienation of property other than such

referred to in paragraphs 1, 2, 3 and 4 shall be taxable only in the

Contracting State of which the alienator is a resident.



6. Gains from the alienation of shares or similar

rights of companies or interests in a partnership or

Trust ("trust") that is acquired by an individual who has

resident in a Contracting State a resident of the

the other Contracting State may, by way of

the provisions of paragraph 5 to be taxed in the first State

If the transfer occurs at any time during the seven years

immediately after the date on which the individual has

ceased to be resident in that State. Such profit

shall not, however, include any gain arising

during the time the person has been a resident of the other

Contracting State.



Article 14



Income from employment



1. the provisions of articles 15, 17 and 18

causing the other, taxable wages and other similar remuneration

as a resident of a Contracting State carries on

account of employment, only in that State unless the

the work is performed in the other Contracting State. If the work

are performed in that other State, receives compensation received for

the work taxed there.



2. Notwithstanding the provisions of paragraph 1 shall be taxable

compensation, as a person resident in one Contracting State

claiming for work in the other Contracting State, only in

the first-mentioned State, if:




a) recipient residing in the other State during the time period

or periods the total of which does not exceed 183 days

during a 12-month period commencing or ending in the

the tax year in question,



b) the remuneration is paid by the employer who is not domiciled

in the other State or on his behalf, and



c) compensation does not affect the permanent establishment

the employer has in the other State.



3. Notwithstanding the preceding provisions of this article shall

compensation paid by a resident of a Contracting State

receipt for work performed on board the ship or aircraft

used in international traffic (in cases other than onboard

on the ship or aircraft used exclusively between

places in the other Contracting State shall be taxable only in)

This state.



Article 15



Directors ' fees



Directors ' fees and other similar remuneration-person marketing

resident in one Contracting State receives as

Member of the Board or other similar bodies in companies with

resident in the other Contracting State, may be taxed in the

that other State.



Article 16



Artists and athletes



1. Notwithstanding the provisions of article 14, income,

as a resident of a Contracting State acquires

through their personal business in the other Contracting

the State acting as artist, such as theatre or

movie actor, radio or television artist, or

musicians, or athletes, be taxed in that

other State.



2. In cases where the income through personal activities as an artist

or sport enthusiasts conducts as such do not accrue

artist or sportutövaren itself without any other person, may

This income, notwithstanding the provisions of article 14,

be taxed in the Contracting State in which the artist or

sportutövaren conducts business.



Article 17



Pensions, annuities and similar payments



1. Pensions and other similar remuneration (including

life interest) derived from a Contracting State, and

payments under social-försäkringslagstiftningen in a

Contracting State may be taxed in that State.



2. The term "annuity" means a fixed amount,

paid periodically at specified times during a

person's lifetime or during a specified or ascertainable

period of time and that is because of the obligation to

the effect, however, these payments as compensation for

fully corresponding consideration in money or money value.



Article 18



Public service



1. a) salaries and other similar remuneration, other than

pension, paid by a Contracting State, one of its

political subdivisions or local authorities to

natural person on the basis of the work done in this State,

the section or Government service, shall be taxable only in

This state.



b) Such salary and other similar remuneration shall be taxable

However only in the other Contracting State if the

the work is performed in that other State and the person concerned has

a resident of this State and:



1) is a national of that State, or



2) were not allowed to live in this State solely for the purpose of performing

the work,



and is taxed in that State, for such salaries and other similar

compensation.



2. the provisions of articles 14, 15 and 16 shall apply to remuneration

and other similar remuneration paid for work

carried out in connection with business carried on by a

Contracting State, one of its political subdivisions

or local authorities.



Article 19



Students



A student or business trainee who is, or immediately

before visiting a Contracting State a resident of the

other Contracting State and who is staying in the former

State exclusively for their education or training,

not subject to tax in that State, for the amount that he receives for

his livelihood, his teaching or training, on the amounts

derived from sources outside that State.



Article 20



Other income



1. income as a resident of a Contracting State

are entitled to and which are not dealt with in the foregoing articles of

This agreement shall be taxable only in that State, regardless of where

the income is derived.



2. Notwithstanding the provisions of paragraph 1, the amount, which

paid to a resident of a Contracting State from

income received by trustees or personal

representatives and manages estates resident in the other

Contracting State, be deemed to originate from the same source and in

the same proportions as the income received by

the trustees or personal representatives and from

the payment is made.



Tax paid by trustees or personal

representatives of income payable to beneficiaries,

be deemed to be paid by the beneficiary.



3. the provisions of paragraph 1 shall not apply to other income,

than income from immovable property referred to in article 6, paragraph 2, of

the beneficial owner of the income is resident in a

Contracting State, carries on business in the other

Contracting State through permanent establishment situated there as well as

the right or property in respect of which the income

paid owns truly connected with the permanent establishment. In

such cases, the applicable provisions of article 7.



4. where, by reason of a special relationship between the person

resident referred to in paragraph 1 and any other person or

between both of them and some other person, the income referred to in

that paragraph exceeds the amount which would have been agreed

between them if such links do not exist, the

the provisions of this article only on the latter amount. In

such cases are taxable surplus amount referred to in

the law of each Contracting State with

observance of the other provisions of the agreement.



5. Relief under this article shall not be obtained if the

main purpose or one of the main objectives, in

any person who has influence over the creation or

the placement of the rights due to which revenues

paid, is to obtain the benefit of this article, such

creation or placement.



Article 21



Avoidance of double taxation



1. in the case of Sweden, double taxation shall be avoided in

the following ways:



a) where a resident of Sweden receives income that

According to the legislation in force in the United Kingdom and in accordance

with the provisions of this agreement, may be taxed in the United

Kingdom of Sweden, – having regard to the provisions of

Swedish legislation relating to the deduction of foreign taxes

(also in the version in the future can get through to change without

that the general principle as stated this change) – from the

Swedish tax on income offset an amount equivalent

the tax in the United Kingdom which paid on income.



b) where a resident of Sweden receives income that in

accordance with this Agreement shall be taxable only in the United

the Kingdom of Sweden may, when determining the tax rate

for Swedish progressive tax, take into account the income to be

shall be taxable only in the United Kingdom.



c) Notwithstanding the provisions of subparagraph (a)) in this paragraph is

dividends from companies established in the United Kingdom to

companies established in Sweden exempt from Swedish tax

According to the provisions of Swedish law on tax exemptions for

dividends paid to Swedish companies by companies in

the rest of the world.



2. In accordance with United Kingdom legislation

regarding the deduction from tax in the United Kingdom of

tax paid in the other State, or exemption

in the United Kingdom regarding dividend with a source in different

State or income from a permanent establishment situated in the other State

(the law does not affect the general principle

listed here):



a) Swedish tax according to Swedish law and in

compliance with this agreement will be paid, either directly

or by deduction, on income or taxable

the capital gain from the source in Sweden (with the exception, in case of

dividends, the tax on profits of which the dividend is paid),

deducted from any income tax in the United Kingdom, which

charged on the same income or taxable capital gain

for which the Swedish tax calculated,



b) dividends paid by a company resident in Sweden for companies with

resident in the United Kingdom shall be exempt from

tax in the United Kingdom when the exemption is

apply and the conditions for exemption under

legislation in the United Kingdom are met,



c) income is acquired by a permanent establishment in Sweden

for a company resident in the United Kingdom should be

exempt from tax in the United Kingdom when

the exemption is applicable and when the conditions of

exemption under the legislation in force in the United Kingdom is

met,



d) if the dividend is not exempt from tax under

paragraph (b)) above are paid by a company resident in Sweden to

a company resident in the United Kingdom

controls, directly or indirectly, at least 10% of the

the number of company, the Swedish tax

the company paid on the profits of which the dividends are paid shall be taken into account

at the settlement under a) of this paragraph.



3. For the purposes of paragraphs 1 and 2, income or

profits acquired by a resident of a Contracting

State and that under this agreement may be taxed in the other

Contracting State shall be deemed to originate from that other State.



4. If a resident of a Contracting State receives

profits may be taxed in the other Contracting State

in accordance with the provisions of article 13, paragraph 6, and such profit

is attributable to:



a) such shares or similar rights referred to in

Article 13 paragraph 2 and the immovable property in question is situated


in the first-mentioned Contracting State, or



b) such shares as referred to in article 26, paragraph 7, and

the rights in question is attributable to assets to be

extracted by the exploration or exploitation of the seabed

and its surface or by their natural resources, situated in

the first-mentioned Contracting State,



to the other Contracting State in accordance with the provisions of

paragraphs 1 and 2 allow a deduction or tax credit for the tax

paid on the profits of the first-mentioned Contracting

State.



Article 22



Prohibition of discrimination



1. nationals of a Contracting State shall not, in the second

Contracting State be subject to taxation or

related requirements are of a different kind or more

burdensome than the taxation and related requirements

as a national of that other Contracting State under the same

conditions are or may be subject to.



2. the taxation on a permanent establishment which businesses in a

Contracting State has in the other Contracting State,

in that other State shall not be less favourable than

taxation of a company in the other State, that carries

activities of the same kind.



3. Except where the provisions of article 9, paragraph 1,

Article 11, paragraphs 4 or 5, article 12, paragraph 4, or

5, or article 20, paragraphs 4 or 5 apply, interest rate,

royalty and other payments from the company in a Contracting

State to a resident of the other Contracting

State tax deductible in determining the taxable

the income of such company on the same terms as payment

to a resident of the first State.



4. Enterprises of a Contracting State, the capital of which is wholly or

partly owned or controlled, directly or indirectly, by a

or more persons resident in the other Contracting

State, not in the first State to be the subject of

taxation or related requirements of other

kind or more burdensome than the taxation and thus

coherent requirements as other similar companies in the

first State are or may be subjected.



5. The provisions of this article shall not be considered to confer

the obligation of a Contracting State to provide for physical

people who do not live in the State of such personal

deduction for tax purposes, such exemption or

tax reduction allowed residents in the

State or to its nationals.



Article 23



The procedure for the mutual agreement



1. If a person believes that a Contracting State or both

Contracting States adopted measures which for him

causes or will result in taxation contrary to

the provisions of this agreement, he may, without prejudice to

his right to make use of the remedies contained in these

States ' internal legal systems, present the matter for the

competent authority of the Contracting State in which he has

domicile or, in the case of application of article 22, paragraph

1, in the Contracting State of which he is a national. The matter should

be presented within three years from the time the person in question

learned about the action that gave rise to taxation

contrary to the provisions of the agreement.



2. If the competent authority finds the complaint justified

but cannot achieve a satisfactory

solution, the authority shall seek to resolve the matter by mutual

agreement with the competent authority of the other

Contracting State in order to avoid taxation which

contrary to the agreement. Agreement is implemented

Notwithstanding the time limits in the Contracting States

internal legislation.



3. the competent authorities of the Contracting States shall

by mutual agreement, seek to determine or

doubts arising concerning the interpretation or

the application of the agreement. They can also initiate consultations with a view to

eliminate double taxation in cases not covered by this

agreements.



4. the competent authorities of the Contracting States may

enter into direct relations with each other in order to meet

agreement in the cases specified in the preceding

points.

5. In cases where,



(a)) a person, in accordance with paragraph 1, has made a

request to the competent authority of a Contracting

State on the grounds that the actions of one or both

Contracting States to him has brought about taxation in

violation of the provisions of this agreement, and



(b)) the competent authorities do not, within three years from the notification

to the competent authority of the other Contracting

the State, may reach an agreement to resolve the matter according to the

paragraph 2,



shall, if the person so requests, the remaining outstanding issues in

matter shall be referred to arbitration. Such unresolved

questions should, however, not be referred to arbitration if a

Court in any of the Contracting States have notified

a decision on these issues. The award is binding for

both Contracting States and shall be carried out without barriers

by the time limits in the domestic law of those States,

unless a person directly affected by the matter not

accept the mutual agreement that implements

the award. The competent authorities of the Contracting

States may agree on way to apply

This paragraph.



6. a) the provisions of paragraph 5 shall not apply in cases

concerning article 4, paragraph 3, nor on cases involving

entry of capital into a permanent establishment within the meaning of

Article 7.



b) Notwithstanding the provisions of paragraph 5, a case

not be referred to arbitration if the competent

the authorities of the Contracting States have agreed

that the case should not be determined by

arbitration.



Article 24



Exchange of information



1. the competent authorities of the Contracting States

shall exchange any information likely to be relevant

for the purposes of this agreement, or for

Administration or enforcement of internal law in

question about taxes of every kind and nature levied

for the Contracting States, or of their political

subdivisions or local authorities, on the taxation

According to this legislation is not contrary to the agreement. Exchange

of information is not restricted by articles 1 and 2.



2. information that a Contracting State received under

paragraph 1 shall be treated as secret in the same manner as

information obtained in accordance with the internal law

in this State and shall be disclosed only to persons or

authorities (including courts and administrative bodies)

establishing, receives or collects the taxes

referred to in paragraph 1 or dealing with prosecution or appeal in

These taxes or supervising those

activities. Such persons or authorities shall use the

information only for such purposes. They may disclose

the information in public court proceedings or in

Court decisions. Notwithstanding the above,

information which a Contracting State received be used

other purposes when such information may be used for such

other purposes according to the laws of both Contracting

States and the competent authority of the Contracting

State disclosures permitted such use.



3. the provisions of paragraphs 1 and 2 shall not obligation

for a Contracting State that:



a) take administrative measures derogating from the legislation

and administrative practices in force in that Contracting State, or in the

the other Contracting State,



b) provide information that is not available under

legislation or the usual administrative practice in this

Contracting State or of the other Contracting

the State,



c) supply information which would disclose any

commercial, industrial, commercial or professional secret

or used in the course of trade practice or

information, whose surrender would be contrary to the public

considerations of public policy.



4. Where a Contracting State requests information under this

Article, the other Contracting State shall use the funds

as this State has to obtain the required

the information, even though that other State may not need

information for its own tax purposes.

The obligation in the previous sentence is limited by the provisions

in paragraph 3, but this does not confer a right to a

Contracting State to refuse to provide information exclusively

because this State has no private interest of such

information.



5. the provisions of paragraph 3 are not right for a

Contracting State to decline to supply information

solely because the information is held by a bank,

other financial institution, agent, representative or

managers or information regarding ownership

in a person.



Article 25



Members of the diplomatic mission and consular posts



The provisions of this Agreement shall not affect the privileges at the

taxation which, according to the General rules of international law or

provisions of specific agreements apply

members of the diplomatic mission and consular offices.



Article 26



Provisions that apply to certain activities outside

Coast

1. Notwithstanding the other provisions of this agreement

apply the provisions of this article when the activities (in

This article referred to as "relevant activities") carried out outside

coast in connection with the exploration or exploitation of

the seabed and its subsoil or of their

natural resources, situated in a Contracting State.



2. Enterprises of a Contracting State who carries out the relevant


activities in the other Contracting State is considered – if not

the provisions of paragraphs 3 and 4 of this article shall give rise

otherwise – carrying on business in that other Contracting State

from permanent establishment situated there.



3. Relevant activities of enterprises of a Contracting State

carries on in the other Contracting State during the period

or time periods that do not exceed a total of 30 days during

a twelve-month period does not mean that the motion is considered to be undertaken

from permanent establishment situated there. For the purposes of this

paragraph, the following applies:



a) in the case of enterprises of a Contracting State who carries on

relevant activities in the other Contracting State has

Community of interest with the company, engaging in substantially

a similar activity there, shall be deemed to the former company

engage in any such activities carried out by the latter

the company. However, this does not apply in so far as the latter

operations are conducted during the same time as the first

the company's own operations.



(b)) a company shall be deemed to have commonality with another, if

one enterprise participates directly or indirectly in the management

or control of the other company or own part i

This company's capital, or if the same persons directly or

indirectly involved in the management or control of both

enterprises or own some of both of these corporate capital.



4. income, as a company of a Contracting State acquires

through the transportation of supplies or personnel by ships or

aircraft to the place where the relevant activities are carried out or

through the use of tugs or ships

assists in anchorage in connection with such activities,

be taxable only in that Contracting State.



5. a) unless paragraph (b)) of this paragraph shall give rise to another,

wages and similar remuneration as a person resident in a

Contracting State receives on account of employment which have

connection with relevant activities in the other

Contracting State, to the extent that work is performed outside the

coast in the other Contracting State, be taxed in that

other Contracting State.



b) salaries and similar benefits, as a resident of a

Contracting State receives for work performed

on board the ship or aircraft transporting equipment

or personnel to the place where the relevant activities are carried out in

a Contracting State or because of work being carried out

on board the tug or particular ships assisting in the

anchoring in connection with such activities, shall be taxable only in

the State in which the person is domiciled.



6. Profit acquired by an enterprise of a Contracting

State using:



a) ships or aircraft for the transport of supplies or

staff to the place where the relevant activities are carried out in a

Contracting State, or



b) tugs or ships assisting in the

anchoring in connection with such activities due to

transfer of such ships, aircraft, tugs or

Special vessels that assist in anchoring, to be taxed

only in that Contracting State.



7. Profit as a resident of a Contracting State

acquires the alienation of rights to

assets that can be extracted by the exploration or

the exploitation of the seabed and its subsoil or of their

natural resources situated in the other Contracting State,

including rights in favor of such assets, or

from the transfer of shares, their value or greater

part of their value directly or indirectly from such

rights may be taxed in that other Contracting

State.

Article 27



Bargain skatteregimer



Notwithstanding other provisions of this agreement, for

the case



a) company resident in one Contracting State is mainly

acquires its income from other States



1) from maritime and financial activities, or



2) by head office, the coordination centre or a

entity providing administrative or other services

to a group of companies engaged in operating mainly in

other States, and



b) such income is taxed according to a favourable fiscal regime

significantly lower under the law of this State other than

revenue from similar activities carried out in this

State or by being the head office, the coordination centre

or similar entity providing administrative or

other services to a group of companies that conduct business in

This State,



the provisions of this agreement which allow for derogation from or

reduction of a tax does not apply to income that such

company acquires nor should article 10 paragraph 2 or

Article 21 shall apply to dividends paid by such

companies.



Article 28



Other provisions



In cases where the taxation in accordance with the provision of this agreement in a

Contracting State of income or capital gains be reduced and

a natural person according to the laws in force in the other

Contracting State is taxed on such income or

capital gains to the extent that it is transferred to, or received in

the other Contracting State and not for the whole of its

amount, the tax relief is granted under this agreement

in the first-mentioned Contracting State shall refer to only the portion

of the income or capital gain that is transferred to or

received in the other Contracting State.



Article 29



Date of entry into force



1. the Contracting States shall in writing on diplomatic

way inform each other when the measures taken pursuant to

each State is required to this Agreement shall

enter into force.



2. the agreement shall enter into force on the thirtieth day following that of

the last of these notifications have been received and shall

then apply



a) in Sweden:



1) in respect of withholding taxes, on amounts paid or

tillgodoförs on 1 January of the year immediately following

the date on which the agreement enters into force or later,



2) in respect of other taxes on income, the tax imposed

for tax years beginning on 1 January of the year following

immediately following the date on which the agreement enters into force or later,

and



(b)) in the United Kingdom:



1) in respect of withholding taxes, on amounts paid or

tillgodoförs on 1 January of the year immediately following

the date on which the agreement enters into force or later,



2) in respect of taxes on income and on capital gains, for

tax year that begins on april 6 that comes closest to the

After the date of entry into force of the agreement or later,



3) in the case of corporation tax, for financial years beginning on 1

April, immediately after the date on which the agreement enters into

force or later.



3. Notwithstanding the provisions of paragraph 1, shall

the provisions of article 23 (mutual agreement) and

Article 24 (Exchange of information) apply from

the date of entry into force of the agreement irrespective of the

tax year the case concerns. No case may, however,

shall be referred to arbitration in accordance with the provisions of

Article 23 paragraph 5 (mutual agreement) until

not earlier than three years after the date on which this agreement enters into

force.



4. the agreement between The United Kingdom of United Kingdom

and Northern Ireland and the Government of the Kingdom of Sweden

for the avoidance of double taxation and the prevention of fiscal evasion

with respect to taxes on income and capital gain,

signed in Stockholm on 30 August 1983 (' the earlier

the agreement "), shall cease to apply in respect of each

tax from the date of this agreement in accordance with paragraph 1 of

This article shall apply in respect of current tax,

and shall expire on the last of these days.



5. Notwithstanding the provisions of paragraphs 2 and 4 and

the provisions of article 17, any natural person who

immediately prior to the entry into force of the agreement was the recipient of the

such payments within the scope of article 18 or article 19

paragraph 2 of the previous agreement, choose to comply with the provisions of

the latter articles, and not the provisions of article 17 of the

This agreement still applies to such

payouts. This choice shall apply to the year in which

the choice is made and every subsequent year provided

that choice has not been revoked by the person. When a selection is

been revoked may not new elections made pursuant to this paragraph.



Article 30



Termination



This agreement will remain in force until terminated by a

Contracting State. Each Contracting State may, at the

terminate the agreement through diplomatic channels by

notice to that effect at least six months before the expiry of any

calendar year. In the event of such termination, the agreement ceases to

apply



a) in Sweden:



1) in respect of withholding taxes, on amounts paid or

tillgodoförs on 1 January of the year immediately following

the end of the six-month period or later,



2) in respect of other taxes on income, the tax imposed

for fiscal years beginning January 1 of the year following

immediately following the end of the six-month period or later,

and



(b)) in the United Kingdom:



1) in respect of withholding taxes, on amounts paid or

tillgodoförs on 1 January of the year immediately following

the end of the six-month period or later,



2) in respect of income tax and tax on capital gains, which are

During fiscal years starting on 6 april of the year closest to the

After that, if the notice is given or later,



3) in respect of corporation tax, the tax levied on

tax year that begins on april 1 of the year following

immediately following the date on which the notice is given or later.



In witness whereof the undersigned, being

duly authorized, have signed this agreement.




Done at Stockholm on 26 March 2015, in duplicate in the

English language.



For the Government of the Kingdom of Sweden



Linda Haggren



For the United Kingdom of United Kingdom and Northern Ireland

Government



Paul Johnston