Law (2012:638) On The Tax Agreement Between Sweden And Mauritius

Original Language Title: Lag (2012:638) om skatteavtal mellan Sverige och Mauritius

Subscribe to a Global-Regulation Premium Membership Today!

Key Benefits:

Subscribe Now

Read the untranslated law here: http://rkrattsbaser.gov.se/sfst?bet=2012:638

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 fortune that Sweden and Mauritius signed the 1

December 2011, together with the protocol attached

to the agreement and which are part of this, apply that law here in

the country.



The content of the agreement and the Protocol annexed to the agreement

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



2012:638



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



2. This Act shall apply in respect of



a) withholding taxes, on amounts paid or tillgodoförs 1

January of the year immediately following the date the law takes effect

in effect, or later, and



(b)) other taxes on income, and taxes on capital, on

tax levied for the fiscal year that begins on 1 January

the years immediately after the date on which the Act comes into force

or later.



3. Through law repeals Act (1992:1195) if

double taxation treaties between Sweden and Mauritius.



The repealed Constitution shall, however, continue to apply in

question about



a) withholding taxes, on amounts paid or tillgodoförs before

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

enters into force, and



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

tax years beginning before 1 January of the year following

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



Annex



Convention between the Kingdom of Sweden and the Republic of

Mauritius for the avoidance of double taxation and the

Prevention of fiscal evasion with respect to taxes on income

and on capital



The Government of the Kingdom of Sweden and the Government of

the Republic of Mauritius, 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,

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. In the case of an

item of income derived by or through a person that is fiscally

transparent under the laws of either Contracting State, such

the item shall be considered to be derived by a resident of a State

to the extent that the item is treated for the purposes of the

taxation law of such State as the income of a resident.



Article 2



Taxes covered



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

capital 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

all taxes imposed on total income, on total capital, or on

elements of income or of capital, including taxes on gains from

the alienation of movable or immovable property, as well as

taxes on capital appreciation.



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



(a) In Mauritius: the income tax



(hereinafter referred to as "Mauritius tax");



(b) 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.);



(v) the municipal income tax (municipal income tax);

and



(vi) the net wealth tax (the State property tax)



(hereinafter referred to as "Swedish 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 which have been made in their respective

taxation laws.



Article 3



General definition



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

otherwise requires:



(a) the term "Mauritius" means all the territories, including

all the islands, which, in accordance with the laws of

Mauritius, constitute the State of Mauritius and includes:



(i) the territorial sea of Mauritius; and (ii) any area outside

the territorial sea of Mauritius which in accordance with

international law has been or may hereafter be designated,

under the laws of Mauritius relating to the Continental Shelf

as an area within which the rights of Mauritius with respect to

the sea, the sea bed and sub-soil and their natural resources

may be exercised;



(b) 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 maritime areas

over which Sweden in accordance with international law

exercises sovereign rights or jurisdiction;



(c) the term "person" includes an individual, a company and any

other body of persons;



(d) the term "company" means any body corporate or any entity

that is treated as a body corporate for tax purposes;



(e) the term "enterprise" applies to the carrying on of any

business;



(f) 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;



(g) the term "international traffic" means any transport by a

ship or aircraft operated by an enterprise of a Contracting

State, except when the ship or aircraft is operated solely

between places in the other Contracting State;



(h) the term "national" means:



(i) any individual possessing the nationality or citizenship of

(a) the Contracting State;



(ii) any legal person, partnership or association deriving its

status as such from the laws in force in a Contracting State;



(i) the term "competent authority" means: (i) in Mauritius, the

Minister to whom the responsibility for the subject of finance

is assigned, his authorized representative or the authority

which is designated as a competent authority for the purposes

of this Convention;



(ii) in Sweden, the Minister of Finance, his authorized

representative or the authority which is designated as a

competent authority for the purposes of this Convention;



(j) 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 or any other criterion of a

similar nature, and also includes that State, any governmental

body or agency, political subdivision or local authority

thereof. The term "resident of a Contracting State" does not

include any person who is liable to tax in that State in

respect only of income from sources in that State or capital

situated therein.



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 has not 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, the competent authorities of the Contracting States

shall endeavour to settle the question by mutual agreement.



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 a construction, assembly or installation

project or supervisory activities in connection therewith

constitutes a permanent establishment only if it load for 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, by that enterprise;



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

combination of activities mentioned in sub paragraphs (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 in the name of the enterprise,

that enterprise shall be deemed to have a permanent

Re-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 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

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

the 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 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. The 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 of the enterprise may be

taxed in the other State but only so much of them as is

attributable to that permanent establishment.



2. Subject to the provisions of paragraph 3, where an

Enterprise of a Contracting State carries on business in the

other Contracting State through a permanent establishment

situated therein, there shall in each Contracting State be

attributed to that permanent establishment the profits which it

might be expected to make if it were a distinct and separate

enterprise engaged in the same or similar activities under the

the same or similar conditions and dealing wholly independently

with the enterprise of which it is a permanent establishment.



3. In determining the profits of a permanent establishment,

There shall be allowed as deductions expenses which are

incurred for the purposes of the business of the permanent

establishment, including executive and general administrative

expenses so incurred, whether in the State in which the

permanent establishment is situated or elsewhere.



4. No profits shall be attributed to a permanent establishment

by reason of the mere purchase by that permanent establishment

of goods or merchandise for the enterprise.



5. For the purposes of the preceding paragraphs, the profits to

be attributed to the permanent establishment shall be

determined by the same method year by year unless there is good

and sufficient reason to the contrary.



6. Where profits include items of income which are dealt with

separately in other Articles of this Convention, then the

the provisions of those Articles shall not be affected by the

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. For the purposes of this Article the expression "operation

of ships or aircraft "by an enterprise, also includes:



(i) the charter or rental on a bare boat basis of ships and

aircraft, and

(ii) the rental of containers and related equipment;



If that charter or rental is incidental to the operation by the

Enterprise of ships or aircraft in international traffic.



3. 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.



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. Where:



(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 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 enterprise of the

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 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, such dividends may also be taxed in the Contracting

State of which the company paying the dividends is a resident

and according to the laws of that State, but if the beneficial

owner of the dividends is a resident of the other Contracting

State, the tax so charged shall not exceed 15 per cent of the

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

is a company (other than a partnership) which holds 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.



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 debtclaims,

participating in profits, as well as income from other

corporate rights which is subjected to the same taxation

treatment as income from shares by the 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 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

the 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 such other State.



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.



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 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, having regard to the debt-

claim for which it is paid, exceeds 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 laws of each Contracting State, due regard being had to

the other provisions of this Convention.



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

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

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, having regard to the use,

right or information for which they are paid, exceeds the

the amount which would have been agreed upon by the payer and the

beneficial owner in the absence of such relationship, the

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 laws of each Contracting

State, due regard being had to the other provisions of this

Convention.



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, or from the alienation

of shares in a company the assets of which consist principally

of such property, may be taxed in that other State.



2. 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.



3. Gains derived by a resident of a Contracting State from the

alienation of ships or aircraft operated in international

traffic or movable property pertaining to the operation of such

ships or aircraft, shall be taxable only in that 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.



4. Gains from the alienation of any property other than that

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

the Contracting State of which the alienator is a resident.



5. Notwithstanding the provisions of paragraph 4, gains from

the alienation of any property derived by an individual 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

the first-mentioned State if the alienation of the property occurs

at any time during the ten years next following the date on

which the individual has ceased to be a resident of the first-

mentioned 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

the 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

period not exceeding in the aggregate183 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 in respect of an employment exercised

aboard a ship or aircraft operated in international traffic by

an enterprise of a Contracting State may be taxed in that

State. Where a resident of Sweden derives remuneration in

respect of an employment exercised aboard an aircraft operated

in international traffic by the air transport consortium

Scandinavian Airlines System (SAS), such remuneration shall be

taxable only in Sweden.



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 Articles 7 and 14, income

derived by a resident of a Contracting State as an artiste,

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 artiste or a sportsman in his capacity as such accrues not

to the artiste or sportsman himself but to another person, that

income may, notwithstanding the provisions of Articles 7 and

14, be taxed in the Contracting State in which the activities

of the artiste or sportsman are exercised.



3. The provisions of paragraphs 1 and 2 shall not apply to

income derived from activities exercised in a Contracting State

by an artiste or a sportsman if the visit to that State is

wholly supported by public funds of the other Contracting

State. In such case, the income shall be taxable only in the

Contracting State in which the artiste or sportsman is a

resident.



Article 17



Pensions, annuities and similar payments



1. Pensions and other similar remuneration, disbursements under the

the Social Security legislation and annuities arising in a

Contracting State and paid to a resident of the other

Contracting State may be taxed in the first-mentioned

Contracting 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.



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

remuneration in respect of services rendered in connection with

a business carried on by a 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 of 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. 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 recipient 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

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

apply.



Article 21



Capital



1. Capital represented by immovable property referred to in

Article 6, owned by a resident of a Contracting State and

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

other State.



2. Capital represented by 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 may be taxed in that other State.



3. Capital represented by ships and aircraft operated in

international traffic by an enterprise of a Contracting State

and by movable property pertaining to the operation of such

ships and aircraft, shall be taxable only in that State.



With respect to capital owned by the air transport consortium

Scandinavian Airlines System (SAS), the provisions of this

paragraph shall apply only to such part of the capital as

corresponds to the participation held in that consortium by SAS

Sweden AB, the Swedish partner of SAS.



4. All other elements of capital of a resident of a Contracting

State shall be taxable only in that State.



5. If, pursuant to paragraph 4 of this Article, the right to

tax-free capital held by an individual who is resident of a

Contracting State, is vested only in that State, such capital

may be taxed in the other Contracting State, where the net

capital is not subject to a general tax on net capital

According to the laws of the first-mentioned State.



Article 22



Elimination of double taxation



1. In the case of Mauritius, double taxation shall be

eliminated as follows:



(a) Where a resident of Mauritius derives income from Sweden

the amount of tax on that income payable in Sweden in

accordance with the provisions of this Agreement may be

credited against the Mauritius tax imposed on that resident.



(b) Where a company which is a resident of Canada pays a

dividend to a resident of Mauritius who controls, directly or

indirectly, at least



5 per cent of the capital of the company paying the dividend,

the credit shall take into account (in addition to any Swedish

tax for which credit may be allowed under the provisions of

subparagraph (a) of this paragraph) the Swedish tax payable by

the first-mentioned company in respect of the profits out of

which such dividend is paid.



Provided that any credit allowed under subparagraphs (a) and

(b) shall not exceed the Mauritius tax (as computed before

allowing any such credit), which is appropriate to the profits

or income derived from sources within Canada.



2. 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 Mauritius and in accordance with the provisions of this

Convention may be taxed in Mauritius, Sweden shall allow-

subject to the provisions of the laws of Sweden concerning

credit for foreign tax (as it 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 Mauritius

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 Mauritius, Sweden may, when determining the

graduated rate of Swedish tax, take into account the income

which shall be taxable only in Mauritius. (c) Notwithstanding

the provisions of sub-paragraph (a) of this paragraph,

dividends paid by a company which is a resident of Mauritius 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. (d) Where a resident of Sweden

owns capital which, in accordance with the provisions of this

Convention, may be taxed in Mauritius, Sweden shall allow as a

deduction from the tax on the capital of that resident an

amount equal to the capital tax paid in Mauritius. Such

deduction shall not, however, exceed that part of the Swedish

capital tax, as computed before the deduction is given, which

is attributable to the capital which may be taxed in Mauritius.



Article 23



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 are or may be subjected.

This provision shall, notwithstanding the provisions of Article

1, also apply to persons who are not residents of one or both

of the Contracting States.



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. This provision shall not be

construed as obliging a Contracting State to grant to residents

of the other Contracting State any personal allowances, reliefs

or reductions for taxation purposes on account of civil status

or family responsibilities which it grants to its own

residents.



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

paragraph 4 of Article 11, or paragraph 4 of Article 12, 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

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. Similarly, any debts of an enterprise of

a Contracting State to a resident of the other Contracting

State shall, for the purpose of determining the taxable capital

of such enterprise, be deductible under the same conditions as

If they had been contracted to a resident of the firstmentioned

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 subject in the firstmentioned 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 first-mentioned State

are or may be subjected.



5. The provisions of this Article shall, notwithstanding the

the provisions of Article 2, apply to taxes of every kind and

Description.



Article 24



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 23,

to that of the Contracting State of which he is a national. The

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.



Article 25



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,

or 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.



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 bond 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 26



Limitations of benefits



Notwithstanding any other provisions of this Convention, where



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

its income primarily from other States



(i) from activities such as financial services or shipping; or



(ii) 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

primarily in other States; and (b) such income would bear a

significantly lower tax under the laws of that State than

income from similar activities carried out within that State or

from being the headquarters, co-ordination centre or similar

the 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 duty shall not apply to the

the income of such company and to the dividends paid by such

company.



Article 27



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 provisions of

Special agreements.



Article 28



Entry into force



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

writing 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



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

credited on or after the first day of January of the year next

following the date on which the Convention enters into force;



(ii) in respect of other taxes on income, and taxes on capital,

on taxes chargeable for any tax year beginning on or after the

first day of January of the year next following the date on

which the Convention enters into force.



3. The Convention between the Government of Canada and the

The Government of Mauritius for the avoidance of double taxation

and the prevention of fiscal evasion with respect to taxes on

income and on capital gains signed on 23 April 1992 (the 1992

Convention) shall terminate upon the entry into force of this

Convention. However, the provisions of the 1992 Convention

shall remain effective until the provisions of this Convention,

in accordance with the provisions of paragraph 2 of this

Article, shall have effect.



Article 29



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



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

credited on or after the first day of January of the year next

following the end of the six month period;



(ii) in respect of other taxes on income, and taxes on capital,

on 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.



In witness whereof the undersigned, being duly authorized

thereto, have signed this Convention.



Done at Paris, this 1st day of December 2011, in duplicate in

the English language.



For the Government of the Kingdom of Sweden



Gunnar Lund



For the Government of the Republic of Mauritius



Jacques Chasteau de Balyon



Protocol



At the signing of the Convention between the Kingdom of Sweden

and the Republic of Mauritius for the avoidance of double

taxation and the prevention of fiscal evasion with respect to

taxes on income and on capital, the Contracting States have

agreed upon the following provisions, which shall form an

integral part of the Convention:



With respect to Article 26, it is understood that

(a) the provisions of that Article shall apply to the income

of, and to the dividends paid by a company



(i) entitled to the preferential treatment as regards credit

for foreign tax under regulation 8 (3) of the Mauritius Income

Tax (Foreign Tax Credit) Regulations 1996, or (ii) referred to

in section 73A of the Mauritius Income Tax Act 1995, or (iii)

covered by any law substantially similar to the laws mentioned

in (i) or (ii), enacted after the date of signature of this

Convention; and



(b) the term "financial services" shall include banking,

financing, insurance, assets management, custodian services,

distribution of financial products, brokerage, pension scheme

management, retirement benefits scheme management and treasury

management.



In witness whereof the undersigned, being duly authorized

thereto, have signed this Protocol.



Done at Paris, this 1st day of December 2011, in duplicate in

the English language.



For the Government of the Kingdom of Sweden



Gunnar Lund



For the Government of the Republic of Mauritius



Jacques Chasteau de Balyon



(Translation)



Agreement between the Kingdom of Sweden and the Republic of Mauritius for

avoidance of double taxation and the prevention of fiscal evasion

with respect to taxes on income and on capital



The Government of the Kingdom of Sweden and the Republic of Mauritius

Government, 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

the following:



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. income which are acquired by, or by a person

whose income according to the legislation of either Contracting

the State is the subject of shareholder taxation, shall be considered as acquired

by a resident of one of the States to the extent that

income, according to the tax laws of this State, shall be treated

as the income of a resident of the State in question.



Article 2



Taxes covered by the agreement



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

wealth that accrues to a Contracting State, its

political underavdelningars or local authorities,

regardless of the way in which taxes are levied.



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

taxes levied on income or on capital in its

entirety or on elements of income or wealth, in that

including taxes on gains from the alienation of movable


or immovable property, as well as taxes on capital appreciation.



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



a) in Mauritius: income tax,



(hereinafter called "Mauritian tax");



b) in Sweden:



1) state income tax,



2) withholding tax,



3) the Special income tax for non-residents,



4) the Special income tax for non-resident artists

et al.,



5) the municipal income tax, and



6) State property tax,

(referred to below as "Swedish tax").



4. the agreement also apply to taxes for the same or essentially

Similarly, after the signing of the agreement accrue at

addition to or in place of the taxes listed in paragraph 3. The

competent authorities of the Contracting States shall communicate to the

each other the essential changes to the respective

tax legislation.



Article 3



General definitions



1. Unless the context gives rise to different, have in the application

by this agreement the following expressions the following meaning:



a) "Mauritius" refers to all territory, infattande all of the Islands, as

in accordance with the legislation of Mauritius constitute State

Mauritius and includes:



1) Mauritius territorial waters, and



2) any area outside the territorial waters of Mauritius in

accordance with the rules of international law are designated or later

will be designated, in accordance with the Mauritius legislation on

the continental shelf, as an area within which Mauritius owns

exercise rights with respect to the sea, the seabed and its

surfaces and its natural resources,



b) "Sweden" means the Kingdom of Sweden and the includes, when

the expression is used in the geographical sense, the territory of Sweden,

Sweden's territorial sea and other maritime areas over which the

Sweden – in accordance with the rules of international law-exercise

sovereign rights or jurisdiction;



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

Association,



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

taxation is treated as a legal person,



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



f) "enterprise of a Contracting State" and "enterprise of the other

Contracting State "refers to the business carried on by a person

resident in one Contracting State, the respective companies

conducted by the resident of the other Contracting

the State,



g) "international transport" means transport by ship or

aircraft used by an enterprise of a Contracting State

except when the ship or aircraft are used exclusively between

places in the other Contracting State,



h) "national" means:



1) natural person which has the nationality of a Contracting State



2) any legal person, partnership or other association

incorporated under the law of a Contracting

State,



in) "competent authority" means:



1) in Mauritius, the Mauritius Finance Minister responsible,

his authorised representative or the authority which

be required to be a competent authority for the purposes of this

agreements,



2) 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,



j) "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 term "person with

resident in one Contracting State "person under

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

domicile, residence, place of management or any other

similar circumstances and also includes that State, its

public-sector bodies or institutions, political

subdivisions or local authorities. The expression "person

resident in one Contracting State "includes, however,

not the person who is liable to tax in that State only for income

from sources in that State or capital situated therein.



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

a resident of both Contracting States, is determined his residence on

the following ways:



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

permanently available to him. If he has a

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

State with which his personal and economic relations are

the strongest (Centre of life interests),



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

their living interests or if he's not in either State have

a dwelling that is permanently available to him, shall be deemed to

he be a resident only of the State where he usually resides,



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

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

only in the State of 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 seek rule by mutual

agreement.



Article 5



Permanent establishment



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

establishment means a fixed place of business, from

What a business is wholly or partly carried on.



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 of

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 shall be deemed to

the term "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 to) stock in trade solely

for working or processing by another company

merchandise,



d) holding of fixed place of business

exclusively for the purchase of goods or obtaining information

for 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 that an enterprise of a Contracting

State carries on in the other Contracting State, if the project

conducted in conjunction with the company's delivery of machines or

equipment,



g) holding of fixed place of business

exclusively for combining activities listed in (a)) to

f) above, provided that all the activities

conducted from the permanent place of business in

because of this combination is of a preparatory or auxiliary

art.



5. If a person who is not an independent representative

at which point 6 applies – and works for a company, as well as in

a Contracting State and which are regularly using

authority to conclude contracts in the name of company, company is considered –

Notwithstanding the provisions of paragraphs 1 and 2 to have fixed

place of business in that State in respect of any activities which

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

the activities of such person are limited to that

set out in paragraph 4 and which, if it was done from a permanent

place of business, would not make this

fixed place of business to the permanent 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

others.



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 State, may

be taxed in that other State.



2. The term "immovable property" has the meaning the term has

According to the legislation of the Contracting State in which the property

is located. However, the term always includes accessories

immovable property, the living and the dead furniture in agriculture and


forestry, rights to which the provisions of private law

If immovable property apply, buildings, tenancies of immovable

property, and the right of 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 apply on income acquired

through immediate use, through rental or other

use of immovable property.



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

of 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 enterprise

carries on business in the other Contracting State from where

permanent establishment situated. If the enterprise carries on business just now

specified manner, the company's income is taxed in the other

the State, but only so much thereof as is attributable to that

permanent establishment.



2. enterprises of a Contracting State carries on business in the

other Contracting State from where the permanent establishment situated

are entered, unless the provisions of paragraph 3 shall give rise to another, in

Each Contracting State to the permanent establishment the

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

If it was a standalone company, which is operated by

the same or similar nature under the same or similar conditions

and independently completed the business with the undertaking to which the

establishment belongs.



3. In determining permanent establishment income deduction is allowed

for expenses incurred for the permanent establishment, including

included expenses for management and General

management, whether the expenditure incurred in the State in which the

permanent establishment is situated or elsewhere.



4. income not attributable to a permanent establishment by reason only of the

the reason to purchase goods through the permanent establishment

merchandise for the enterprise.



5. for the purposes of the preceding paragraphs, income is determined as

is attributable to the permanent establishment by the same procedure

from year to year, unless good and sufficient reasons causing the

other things.



6. Included in income by operating income which are dealt with in particular in

other articles of this agreement, the provisions of these

articles of the rules contained in 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. For the purposes of this article includes the phrase

"the use by ships or aircraft of a company:



1) charter or rental of ships or aircraft on so-called

bare boat basis, and



2) the rental of containers and related equipment,



provided that such charter or rental is of

secondary importance, in relation to the company's use

of ships or aircraft in international traffic.



3. the provisions of paragraph 1 shall apply to income acquired

of the air transport Consortium Scandinavian Airlines System (SAS) but

only in the case of that part of the income corresponding to the proportion

of the Consortium held by SAS Sweden AB, the Swedish

shareholder in SAS.



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 the



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

participate in the management or control of a company in the other

Contracting State or owns part of the company capital,

or



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

or control of an enterprise of a Contracting State

as an enterprise of the other Contracting State or own

part in 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 independent

companies, receives all the income, that without such conditions would have

added one company but because of the conditions in

ask not this company, is included in this business

income and taxed accordingly.



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

State include – and taxes accordingly –

income, for which an enterprise of the other Contracting

State is taxed in the other State, and it thus

ancillary income is that which would have been companies in

the first State on the terms agreed between

the enterprises had been those which would have been agreed between the

independent enterprises, then that other State conduct

proper adjustment of the amount of tax imposed on the income

there. When such adjustments are complied with the other 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 may be

taxed in the Contracting State in which the company

paying the dividends is a resident, according to the law of that

State, but if the beneficial owner of the dividends is a resident of

the other Contracting State, the tax shall not exceed 15

per cent of the gross amount of the dividends. Such dividend shall

However, be exempt from taxation in the State of

the company paying the dividends is a resident, if the

entitled to dividends is a company (with the exception of

a partnership) which holds at least 10 per cent of the distributing

the company's voting power. The provisions of this paragraph shall not affect

the company's taxation of the gain of the dividend

paid.



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

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

right to share in profits, as well as income from other investments in companies

who, under the law of the State in which the distributing company

is resident for tax purposes shall be treated in the same way as

income from shares.



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

entitled to the dividends is a resident of a Contracting State

and carries on business in the other Contracting State, where the

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

permanent establishment, and the proportion due to the dividend payment

paid owns truly connected with the permanent establishment. In

such cases shall apply 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 not distributed profits take off

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

the dividend or the undistributed profits wholly or partly

consists of income arising in that other State.



Article 11



Interest rate



1. interest, stemming from a Contracting State and which

paid to a resident of the other Contracting

State, shall be taxable only in that other State if the person concerned

is entitled to the interest.



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

each kind of claim, whether secured by mortgage

in immovable property or not, and whether it entails the right to

interest in the debtor's profits or not. The term refers to the particular

income from securities issued by State and

bonds or debentures, including premiums and

profits pertaining to such securities, bonds

or debentures. Penalty for late payment is considered

not that interest for the purposes of this article.



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

the interest rate is a resident of a Contracting State and carries on

on business in the other Contracting State from which the interest

derived from the permanent establishment situated there, and the claim for

the interest rate paid owns actual relation to the Permanent

establishment. In such cases, apply the provisions of article

7.



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

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

person the amount of the interest, having regard to the debt claim for which

the interest is paid, exceeds the amount which would have been agreed

between the payer and the beneficial owner of the interest on 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 of

This agreement.



Article 12



Royalty



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

be paid to the person who is a resident of the other Contracting

State, shall be taxable only in that other State if the person concerned

are entitled to the royalty.



2. The term "royalties" in this article, of course, every kind of

payments received as compensation for the use of, or

for the right to use copyright to literary, artistic

or scientific work, including cinematograph films and


films or tapes for radio or television broadcasting,

patent, trade mark, design or model, plan, secret

recipe or secret manufacturing process, or for information about

experience knowledge of industrial, commercial or scientific

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

are 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, as well as the

right or property in respect of which the royalties are paid is the owner

effectively connected with the permanent establishment. In such a case

apply article 7.



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

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 royalties are payable,

exceeds the amount which would have been agreed between the payer

and the person entitled to the royalty for such relations not

exist, the provisions of this article shall apply only to

the latter amount. In such a case the taxable surplus amount

According to the law of each Contracting State with

observance of the other provisions of this agreement.



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, or because of the disposal of shares in a company whose

assets consists mainly of such property, may be taxed

in that other State.



2. Gains from the alienation of movable property forming part

of the operating assets of a permanent establishment which an enterprise of the

a Contracting State has in the other Contracting State,

may be taxed in that other State. The same applies to the profit of

alienation of such a permanent establishment (alone or

together with the whole enterprise).



3. Profit as a resident of a 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;

shall be taxable only in that State. The provisions of this paragraph

apply in respect of profits acquired by the air transport Consortium

Scandinavian Airlines System (SAS), but only in the case of the

part of the profits as corresponds to the participation in the Consortium held

SAS Sweden AB, the Swedish partner of SAS.



4. Gains from the alienation of property other than that

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

Contracting State of which the alienator is a resident.



5. Profit, due to the disposal of assets, which are acquired by

a natural person who has been domiciled in a Contracting State

and a resident of the other Contracting State shall, without

by way of derogation from paragraph 4 – is taxed in the

first State if the transfer of the asset occurs at

any time during the 10 years immediately after the

date on which the person ceased to be a resident of the first-mentioned

State.



Article 14



Income from employment



1. the provisions of articles 15, 17 and 18 give rise

other, taxable wages and other similar remuneration paid by person

resident in one Contracting State receives due

employment, only in that State unless the work is carried out in

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

other State, compensation received for work are 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

time periods that in total not exceeding 183 days during a

twelve-month period commencing or ending in the

the tax year in question, and



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,

remuneration for work performed on board the ship or

aircraft used in international traffic by an enterprise of

a Contracting State may be taxed in that State, if a person

resident in Sweden receives remuneration for work performed

on board the aircraft used in international transport of

the air transport Consortium Scandinavian Airlines System (SAS),

such remuneration shall be taxable only in Sweden.



Article 15



Directors ' fees



Directors ' fees and other similar remuneration, as a person with

resident in one Contracting State receives as a member of the

Board of the company resident in the other Contracting State,

may be taxed in that other State.



Article 16



Artists and athletes



1. Notwithstanding the provisions of articles 7 and 14,

income, as a resident of a Contracting State

acquire through their personal activities in the other

Contracting State in his capacity as a performer, such as theatre or

movie actor, radio or television artiste, or a musician,

or as athletes, be taxed in that other State.



2. Where income in respect of personal activities exercised by

an artiste or a sportsman in his capacity as such accrues not

to the artiste or sportsman himself but to another person, that

income may, notwithstanding the provisions of Articles 7 and

14, be taxed in the Contracting State in which the activities

of the artiste or sportsman are exercised.



3. The provisions of paragraphs 1 and 2 shall not apply to

income derived from activities exercised in a Contracting State

by an artiste or a sportsman if the visit to that State is

wholly supported by public funds of the other Contracting

State. In such case, the income shall be taxable only in the

Contracting State in which the artiste or sportsman is a

resident.



Article 17



Pensions, annuities and similar payments



1. Pensions and other similar remuneration, disbursements under the

the Social Security legislation and annuities arising in a

Contracting State and paid to a resident of the other

Contracting State may be taxed in the first-mentioned

Contracting 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.



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

remuneration in respect of services rendered in connection with

a business carried on by a 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 of 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. 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 recipient 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

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

apply.



Article 21



Capital



1. Capital represented by immovable property referred to in

Article 6, owned by a resident of a Contracting State and

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

other State.



2. Capital represented by 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 may be taxed in that other State.



3. Capital represented by ships and aircraft operated in

international traffic by an enterprise of a Contracting State

and by movable property pertaining to the operation of such

ships and aircraft, shall be taxable only in that State.



With respect to capital owned by the air transport consortium

Scandinavian Airlines System (SAS), the provisions of this

paragraph shall apply only to such part of the capital as

corresponds to the participation held in that consortium by SAS

Sweden AB, the Swedish partner of SAS.




4. All other elements of capital of a resident of a Contracting

State shall be taxable only in that State.



5. If, pursuant to paragraph 4 of this Article, the right to

tax-free capital held by an individual who is resident of a

Contracting State, is vested only in that State, such capital

may be taxed in the other Contracting State, where the net

capital is not subject to a general tax on net capital

According to the laws of the first-mentioned State.



Article 22



Elimination of double taxation



1. In the case of Mauritius, double taxation shall be

eliminated as follows:



(a) Where a resident of Mauritius derives income from Sweden

the amount of tax on that income payable in Sweden in

accordance with the provisions of this Agreement may be

credited against the Mauritius tax imposed on that resident.



(b) Where a company which is a resident of Canada pays a

dividend to a resident of Mauritius who controls, directly or

indirectly, at least



5 per cent of the capital of the company paying the dividend,

the credit shall take into account (in addition to any Swedish

tax for which credit may be allowed under the provisions of

subparagraph (a) of this paragraph) the Swedish tax payable by

the first-mentioned company in respect of the profits out of

which such dividend is paid.



Provided that any credit allowed under subparagraphs (a) and

(b) shall not exceed the Mauritius tax (as computed before

allowing any such credit), which is appropriate to the profits

or income derived from sources within Canada.



2. 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 Mauritius and in accordance with the provisions of this

Convention may be taxed in Mauritius, Sweden shall allow-

subject to the provisions of the laws of Sweden concerning

credit for foreign tax (as it 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 Mauritius

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 Mauritius, Sweden may, when determining the

graduated rate of Swedish tax, take into account the income

which shall be taxable only in Mauritius.



(c) Notwithstanding the provisions of sub-paragraph (a) of this

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

Mauritius 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.



(d) Where a resident of Sweden owns capital which, in

accordance with the provisions of this Convention, may be taxed

in Mauritius, Sweden shall allow as a deduction from the tax on

the capital of that resident an amount equal to the capital tax

paid in Mauritius. Such deduction shall not, however, exceed

that part of the Swedish capital tax, as computed before the

deduction is given, which is attributable to the capital which

may be taxed in Mauritius.



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

or sport enthusiasts conducts as such do not accrue

artist or sportutövaren yourself without the other person, this

income, notwithstanding the provisions of articles 7 and 14,

be taxed in the Contracting State in which the artist or

sportutövaren conducts business.



3. the provisions of paragraphs 1 and 2 shall not apply to

income, as a performer or athletes acquires through its

personal business in a Contracting State, if the artist's

or sportutövarens visit to this State as a whole

financed by the public funds of the other Contracting

State. In such a case the income shall be taxable only in the

Contracting State in which the artist or sportutövaren have

resident.



Article 17



Pensions, annuities and similar payments



1. Pensions and other similar remuneration, payment under

social security legislation and annuities arising from a

Contracting State and paid to a resident of the

the other Contracting State, may be taxed in the

first-mentioned Contracting State.



2. The term "annuity" means a prescribed amount, which

be 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 give effect to these

However, payments made as remuneration for fully answering

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 physical

person because of 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 work is performed in

that other State and the person concerned is resident in that 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.



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

compensation paid on the basis of the 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 trainee who is, or immediately before

stayed in a Contracting State a resident of the other

Contracting State and residing in the first State

exclusively for their education or training, is not taxed

in this State for the amount that he receives for his living,

their education or training, of the amounts derived from the source

outside this State.



Article 20



Other income



1. income as a resident of a Contracting State

acquires and which are not dealt with in the foregoing articles of this

Agreement shall be taxable only in that State, regardless of the origin of income

derived.



2. the provisions of paragraph 1 shall not apply to income, with

excluding income from immovable property referred to in article 6, paragraph

2, if the recipient of the income is resident in a Contracting

State and carries on business in the other Contracting State

from where the permanent establishment situated, as well as the right or

property in respect of which the income is paid owns real

connected with the permanent establishment. In such a case be applied

the provisions of article 7.



Article 21



Fortune



1. Fortune consisting of such immovable property referred to in

Article 6, any person resident in one Contracting State

holds and which is situated in the other Contracting State

may be taxed in that other State. 2. Fortune

consisting of movable property forming part of the business assets

in the permanent establishment which an enterprise of a Contracting State

has in the other Contracting State, may be taxed in that

other State.



3. wealth consisting of ship and aircraft used in the

international traffic by an enterprise of a Contracting State

and of movable property that is attributable to the use of such

ships and aircraft, shall be taxable only in that State.



The provisions of this paragraph shall apply in the case of Fortune

owned by the air transport Consortium Scandinavian Airlines System

(SAS), but only in respect of the portion of assets that

corresponds to the percentage of the Consortium held by SAS Sweden AB,

the Swedish partner of SAS.



4. All other types of fortune as a person resident in a

Contracting State, be taxable only in that State.



5. If, in accordance with paragraph 4 of this article, the right to

taxing wealth held by a resident of a

Contracting State, belongs to this State, this

wealth is taxed in the other Contracting State, if

wealth is not the subject of a general property tax

According to the legislation of the first State.



Article 22



The Elimination of double taxation



1. regarding Mauritius double taxation shall be avoided in

the following ways:



a) where a resident of Mauritius receives income from

Sweden, the tax on income which, in accordance with this

contracts in Sweden, be offset against income tax that the person

paid in Mauritius.



b) where a company established in Sweden pays dividends to a

resident of Mauritius which controls, directly or

indirectly, at least 5% of the company capital,

should be taken into account in the settlement (except such Swedish tax for

the tax credit is to be given under paragraph (a)) above) the Swedish

tax paid on the profits out of which the dividend

paid.



Settlement amount referred to in paragraphs (a) and (b) above))

should not, however, exceed the Mauritian tax

(calculated without such deduction) charged on the income

derived from Sweden.



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

the following ways:



a) where a resident of Sweden acquires income according to

Mauritian legislation and in accordance with the provisions of

This agreement may be taxed in Mauritius, Sweden – with

subject to the provisions of Swedish legislation concerning

deduction of foreign taxes (even in the version in the future

can get through to change without the general principle set out

This change) – from the Swedish tax on income offset a

the Mauritian tax paid on

income.



b) where a resident of Sweden receives income in


accordance with this Agreement shall be taxable only in Mauritius,

Sweden, in determining the tax rate for the Swedish

progressive tax, take into account the income which shall be taxable only in

Mauritius.



c) Notwithstanding the provisions of paragraph (a)) above is dividend

from a company resident in Mauritius to resident companies

Sweden exempt from Swedish tax according to the provisions of

the Swedish exemption for dividends paid to

Swedish companies by companies abroad.



(d)) where a resident of Sweden owns capital,

in accordance with the provisions of this agreement may be taxed in Mauritius,

to Sweden from the tax on that person's fortune set off

an amount equal to the capital tax paid in

Mauritius. Settlement amount shall not, however, exceed the

part of the Swedish wealth tax, calculated without such

settlement, charged on the fortune that may be taxed in the

Mauritius.



Article 23



Prohibition of discrimination



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

Contracting State be subject to taxation or

coherent demands that are of a different kind or more onerous than

the taxation and related requirements as nationals of

the other State under the same circumstances are or may be

subject to. Notwithstanding the provisions of article 1

This provision also applies to any person who is not domiciled

of a Contracting State or in both Contracting States.



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

Contracting State has in the other Contracting State, shall

in that other State shall not be less favourable than

taxation of the company in the other State, that carries

activities of the same kind. This provision is not considered to cause

the obligation of a Contracting State to grant to individuals with

resident in the other Contracting State such personal

deduction for tax purposes, such exemption or

tax reduction on the basis of marital status or

dependants permitted residents in their own

State.



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

Article 11 paragraph 4 or article 12 paragraph 4 applies, the

interest, royalties and other payments from the company in a

Contracting State to a resident of the other

Contracting State, tax deductible in determining the

taxable income of such company on the same terms and conditions

as payment to a resident of the first State.

Similarly, debt as a company of a Contracting State has

to a resident of the other Contracting State

deductible in determining such taxable

fortune on the same basis as liability to a resident

in 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. Notwithstanding the provisions of article 2 shall be applied

the provisions of this article on the taxes of every kind and

nature.



Article 24



Mutual agreement procedure



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

Contracting States took measures to 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 23, 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

Unable to achieve a satisfactory solution,

authority to resolve the matter by mutual agreement

with the competent authority of the other Contracting State

in order to avoid taxation which is contrary to the agreement.

Agreement is carried out without prejudice

time limits in the domestic law of the Contracting States.



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 paragraphs.



Article 25



Exchange of information



1. the competent authorities of the Contracting States shall

Exchange such information likely to be relevant to the

application of the provisions of this agreement or for

Administration or enforcement of internal law in

question about taxes of every kind and nature, 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. The 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 legislation of the

This State and shall be disclosed only to persons or authorities

(including courts and administrative bodies)

sets, receives or collects the taxes referred to in

paragraph 1 or dealing with prosecution or appeal in respect of

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.



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

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 State,



c) supply information which would disclose any trade secret,

industrial, commercial or professional secret, or in

trade used the process or information,

the surrender would be contrary to ordre public considerations (

public).



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 of paragraph 3, but

This does not mean the right of a Contracting State to refuse

provide information solely because this State has not

any 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 trustee

or because the information concerning the ownership of a person.



Article 26



Limitation of benefits



Notwithstanding other provisions of this agreement, if



a) company resident in one Contracting State acquires its

income primarily from other States



1) from activities such as financial services or

shipping, or



2) by head office, the coordination centre or

similar entity providing administrative or other

services to a group of companies engaged in operating

mainly in other States, and



b) such income is taxed at a significantly lower under

law of this State other than revenue from similar

activities carried out within this State or from being

Head Office, the coordination centre or similar device

provides administrative or other services to a

Group of companies, which carries on business in that State, they shall

provisions of this agreement which allow for derogation from or

reduction of a tax does not apply to income that such a company

acquires nor on dividend paid by such

companies.



Article 27



Diplomatic representatives and consular officials



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 28



Date of entry into force



1. the Contracting States shall notify the

each other when the measures taken under the respective State

legislation is required in order for this agreement to enter into force.



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

the last of these notifications have been received and shall

then apply



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


tillgodoförs on 1 January of the year immediately after the

date of entry into force of the agreement or later,



2) in respect of other taxes on income, and taxes on

Fortune, on tax for taxation years that begin

on 1 January of the year immediately following the date of

the agreement enters into force or later. 3. The agreement between the

The Swedish Government and the Government of Mauritius to avoid

of double taxation and the prevention of fiscal evasion with respect to taxes

on income and capital gains, signed on 23

April 1992 (the 1992 Agreement) shall cease with the entry into force

of this agreement. The provisions of the 1992 agreement, however,

continue to apply until the provisions of this agreement,

in accordance with the provisions of paragraph 2 of this article, start

applied.



Article 29



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



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

tillgodoförs the



1 January of the year immediately following the end of

the six-month period or later,



2) in respect of other taxes on income, and taxes on

Fortune, on the tax for the tax year that

beginning on January 1 of the year immediately following the end

of the six-month period or later.



In witness whereof the undersigned, being duly

authorised, have signed this agreement.



Done at Paris on 1 december 2011, in duplicate in the

English language.



For the Government of the Kingdom of Sweden



Gunnar Lund



The Government of the Republic of Mauritius



Jacques Chasteau de Balyon



Protocol



At the signing of the agreement between the Kingdom of Sweden and

The Republic of Mauritius for the avoidance of double taxation and

Prevention of tax evasion with respect to taxes on income and

at Fortune, has the Contracting States have agreed

the following provisions, which shall form an integral part of the

Agreement: in the case of article 26, it is agreed

(a)) that the provisions of the said article apply to income of,

and dividends from, a company



1) are entitled to preferential treatment with regard to settlement

of foreign tax according to the provisions of paragraph 8 (3)

Mauritius Income Tax (Foreign Tax Credit) Regulations 1996,

or



2) referred to in section 73A of the Income Tax Act 1995 in Mauritius, or



3) covered by a law that is essentially similar to the laws

as mentioned in 1) or 2) above and imposed after the date of

the signing of this agreement, and (b)) that the expression

"financial services" includes the banking, financial and

insurance, asset management,

storage services, distribution of financial products,

brokerage, management of pensions and retirement benefits as well as

liquidity management.



In witness whereof the undersigned, being duly

authorised, have signed this Protocol.



Done at Paris on 1 december 2011, in duplicate in the

English language.



For the Government of the Kingdom of Sweden



Gunnar Lund



The Government of the Republic of Mauritius



Jacques Chasteau de Balyon