Law (2009:1124) If Agreement Between Sweden And Guernsey On The Exchange Of Information In Tax Matters

Original Language Title: Lag (2009:1124) om avtal mellan Sverige och Guernsey om utbyte av upplysningar i skatteärenden

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Read the untranslated law here: http://rkrattsbaser.gov.se/sfst?bet=2009:1124

The agreement on Exchange of information in tax matters

The Kingdom of Sweden and Guernsey signed on 28

October 2008 will be valid as law in this country. The agreement is

drafted in English and appears in annex to this law.



Transitional provisions



2009:1124



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



2. this law shall be applied for fiscal years beginning on

1 January of the year following the year in which the law comes into force or

later, or, if the tax year is missing, the tax levied

on 1 January of the year following the year in which the law comes into force or

later. In the cases that make up these matters under the

the agreement will, however, Act apply from the

the entry into force.



Annex



AGREEMENT BETWEEN THE KINGDOM OF SWEDEN AND THE STATES OF GUERNSEY FOR THE EXCHANGE OF INFORMATION RELATING TO TAX MATTERS



Whereas the Government of the Kingdom of Sweden and the States of Guernsey ("the Parties") recognize that present legislation in Guernsey already provides for cooperation and the exchange of information in criminal matters;



Now, therefore, the Parties have agreed to conclude the following Agreement which contains the bond on the part of the Parties only:



Article 1 Scope of the Agreement



The Parties shall provide assistance through exchange of information that is foreseeably relevant to the administration and enforcement of the domestic laws of the Parties concerning taxes covered by this Agreement, including information that is foreseeably relevant to the determination, assessment, recovery and enforcement or collection of tax with respect to persons subject to such taxes, or to the investigation of tax matters or the criminal prosecution of tax matters in relation to such person. A requested Party is not obliged to provide information which is neither held by its authorities nor in the possession of nor obtainable by persons who are within its territorial jurisdiction. The rights and safeguards secured to persons by the laws or administrative practice of the requested Party remain applicable to the extent that they do not unduly prevent or delay effective exchange of information.



Article 2



Taxes covered



1. This Agreement shall apply to the following taxes imposed by the Parties:



(a) in the case of Guernsey:



(i) the income tax; and



(ii) dwellings profits tax;



(b) in the case of 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);



(vi) the yield tax on pension funds (capital yield tax on pension funds).



2. This Agreement shall apply also to any identical taxes imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. This Agreement shall apply also to any substantially similar taxes imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes if the Parties so agree. The competent authority of each Party shall notify the other of substantial changes in laws which may affect the bond of that Party pursuant to this Agreement.



Article 3



Definition



1. In this Agreement: (a) the "Guernsey" means Guernsey, Alderney and Herm, including the territorial sea adjacent to those islands, in accordance with international law;



(b) "United States" 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) "company" means any body corporate or any entity that is treated as a body corporate for tax purposes;



(d) "competent authority" means, in the case of Guernsey, the Administrator of Income Tax or his delegate, and in the case of Canada, the Minister of Finance, his authorised representative or the authority which is designated as a competent authority for the purposes of this Agreement;



(e) "criminal laws" means all criminal laws designated as such under domestic law, irrespective of whether such are contained in the tax laws, the criminal code or other statutes;



(f) "criminal tax matters" means tax matters involving intentional conduct whether before or after the entry into force of this Agreement which is liable to prosecution under the criminal laws of the requesting Party;



(g) "information gathering measures" means laws and administrative or judicial procedures enabling the requested Party to obtain and provide the information requested;



(h) "information" means any fact, statement, document or record in whatever form;



(i) "person" means a natural person, a company or any other body or group of persons;



(j) "publicly traded company" means any company whose principal class of shares is listed on a recognised stock exchange provided its listed shares can be readily purchased or sold by the public. Shares can be purchased or sold "by the public" if the purchase or sale of shares is not implicitly or explicitly restricted to a limited group of investors;



(k) "principal class of shares" means the class or classes of shares representing a majority of the voting power and value of the company;



(l) "public collective investment scheme" means any scheme or fund, in which the purchase, sale or redemption of shares or other interests is not implicitly or explicitly restricted to a limited group of investors;



(m) "recognised stock exchange" means any stock exchange agreed upon by the competent authorities of the Parties;



(n) "requested Party" means the Party to this Agreement which is requested to provide or has provided information in response to a request;



(o) "requesting Party" means the Party to this Agreement submitting a request for or having received information from the requested Party;



(p) "tax" means any tax covered by this Agreement.



2. As regards the application of this Agreement at any time by a Party, 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 Party, any meaning under the applicable tax laws of that Party prevailing over a meaning given to the term under other laws of that Party.



Article 4



Exchange of information upon request



1. The competent authority of the requested Party shall provide upon request by the requesting Party information for the purposes referred to in Article 1. Such information shall be exchanged without regard to whether the requested Party needs such information for its own tax purposes or the conduct being investigated would constitute a crime under the laws of the requested Party if it had occurred in the territory of the requested Party. The competent authority of the requesting Party shall only make a request for information pursuant to this Article when it is unable to obtain the requested information by other means, except where recourse to such means would give rise to disproportionate difficulty.



2. If the information in the possession of the competent authority of the requested Party is not sufficient to enable it to comply with the request for information, the requested Party shall use at its own discretion, all relevant information gathering measures necessary to provide the requesting Party with the information requested, notwithstanding that the requested Party may not need such information for its own tax purposes.



3. If specifically requested by the competent authority of the requesting Party, the competent authority of the requested Party shall provide information under this Article, to the extent allowable under its domestic laws, in the form of depositions of witnesses and authenticated copies of the original records.



4. Each Party shall ensure that it has the authority, subject to the terms of Article 1, to obtain and provide, through its competent authority and upon request:



(a) information held by banks, other financial institutions, and any person, including nominees and trustees, acting in an agency or fiduciary capacity;



(b) (i) information regarding the legal and beneficial ownership of companies, partnerships, foundations and other persons, including in the case of collective investment schemes, information on shares, units and other interests;



(ii) in the case of trusts, information on settlors, trustees, protectors and with; and in the case of foundations, information on founders, members of the foundation council and with.



Further, this Agreement does not create an obligation for a Party to obtain or provide ownership information with respect to publicly traded companies or public collective investment schemes, unless such information can be obtained without giving rise to disproportionate difficulties.



5. Any request for information shall be formulated with the greatest detail possible and shall specify in writing:



(a) the identity of the person under examination or investigation;



(b) the period for which the information is requested;



(c) the nature of the information requested and the form in which the requesting Party would prefer to receive it;



(d) the tax purpose for which the information is sought;



(e) the reasons for believing that the information requested


is foreseeably relevant to tax administration and enforcement of the requesting Party, with respect to the person identified in subparagraph (a) of this paragraph;



(f) the grounds for believing that the information requested is held in the requested Party or is in the possession of or obtainable by a person within the jurisdiction of the requested Party;



(g) to the extent known, the name and address of any person believed to be in possession or control of the information requested;



(h) a statement that the request is in conformity with the laws and administrative practices of the requesting Party, that if the requested information was within the jurisdiction of the requesting Party then the competent authority of the requesting Party would be able to obtain the information under the laws of the requesting Party or in the normal course of administrative practice and that it is in conformity with this Agreement;



(i) a statement that the requesting Party has pursued all means available in its own territory to obtain the information, except those that would give rise to disproportionate difficulty.



6. The competent authority of the requested Party shall acknowledge receipt of the request to the competent authority of the requesting Party and shall use its best endeavour's to forward the requested information to the requesting Party as soon as possible.



Article 5



Tax examination abroad



1. With reasonable notice, the requesting Party may request that the requested Party allow representatives of the competent authority of the requesting Party to enter the territory of the requested Party, to the extent permitted under its domestic laws, to interview individuals and examine records with the written consent of the individuals or other persons concerned. The competent authority of the requesting Party shall notify the competent authority of the requested Party of the time and place of the intended meeting with the individuals concerned.



2. At the request of the competent authority of the requesting Party, the competent authority of the requested Party may permit representatives of the competent authority of the requesting Party to attend a tax examination in the territory of the requested Party.



3. If the request referred to in paragraph 2 is granted, the competent authority of the requested Party conducting the examination shall, as soon as possible, notify the competent authority of the requesting Party of the time and place of the examination, the authority or person authorised to carry out the examination and the procedures and conditions required by the requested Party for the conduct of the examination. All decisions regarding the conduct of the examination shall be made by the requested Party conducting the examination.



Article 6



Possibility of declining a request



1. The competent authority of the requested Party may decline to assist:



(a) where the request is not made in conformity with this Agreement;



(b) where the requesting Party has not pursued all means available in its own territory to obtain the information, except where recourse to such means would give rise to disproportionate difficulty; or



(c) where the disclosure of the information requested would be contrary to public policy (ordre public).



2. This Agreement shall not impose upon a requested Party any obligation to provide items subject to legal privilege, or any trade, business, industrial, commercial or professional secret or trade process, provided that information described in paragraph 4 of Article 4 shall not by reason of that fact alone be treated as such a secret or trade process.



3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed.



4. The requested Party shall not be required to obtain and provide information which if the requested information was within the jurisdiction of the requesting Party, the competent authority of the requesting Party would not be able to obtain under its laws or in the normal course of administrative practice.



5. The requested Party may decline a request for information if the information is requested by the requesting Party to administer or enforce a provision of the tax law of the requesting Party, or any requirement connected therewith, which discriminates against a national or citizen of the requested Party as compared with a national or citizen of the requesting Party in the same circumstances.



Article 7



Confidentiality



1. All the information provided and received by the competent authorities of the Parties shall be kept confidential.



2. Such information shall be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes specified in Article 1, and used by such persons or authorities only for such purposes, including the determination of any appeal. For these purposes, information may be disclosed in public court proceedings or in judicial decisions.



3. Such information may not be used for any purpose other than for the purposes stated in Article 1 without the express written consent of the competent authority of the requested Party.



4. Information provided to a requesting Party under this Agreement may not be disclosed to any other jurisdiction.



Article 8



Costs



Unless the competent authorities of the Parties otherwise agree, ordinary costs incurred in providing assistance shall be borne by the requested Party, and extraordinary costs in providing assistance (including costs of engaging external advisors in connection with litigation or otherwise) shall be borne by the requesting Party. The respective competent authorities shall consult from time to time with regard to this Article, and in particular the competent authority of the requested Party shall consult with the competent authority of the requesting Party in advance if the costs of providing information with respect to a specific request are expected to be significant.



Article 9



Language Requests for assistance and responses thereto shall be drawn up in English.



Article 10



Mutual agreement procedure



1. Where difficulties or doubts arise between the Parties regarding the implementation or interpretation of this Agreement, the respective competent authorities shall use their best efforts to resolve the matter by mutual agreement.



2. In addition to the agreements referred to in paragraph 1, the competent authorities of the Parties may mutually agree on the procedures to be used under Articles 4, 5 and 8.



3. Formal communications, including requests for information, made in connection with or pursuant to the provisions of the Agreement will be entered into in writing directly to the competent authority of the other Party at such address as may be notified by one Party to the other from time to time. Any subsequent communications regarding requests for information will be either in writing or verbally, whichever is most practical, between the earlier mentioned competent authorities or their authorised representatives.



Article 11



Entry into force



This Agreement shall enter into force on the thirtieth day after the later of the dates on which each of the Parties has notified the other in writing that the procedures required by its law have been complied with. The Agreement shall have effect: (a) for criminal tax matters on that date; and



(b) for all other matters covered in Article 1 on that date, but only in respect of any tax year beginning on or after the first day of January of the calendar year next following that in which this Agreement enters into force or, where there is no tax year, all charges to tax arising on or after that date.



Article 12



Termination



1. This Agreement shall remain in force until terminated by either Party.



2. Either Party may terminate the Agreement by giving written notice of termination at least six months before the end of any calendar year. In such event, the Agreement shall cease to have effect on taxes chargeable for any tax year beginning on or after the first day of January of the calendar year next following the end of the six month period. All requests received up to the effective date of termination will be dealt with in accordance with the terms of this Agreement.



3. If the Agreement is terminated the Parties shall remain bound by the provisions of Article 7 with respect to any information obtained under this Agreement.



In witness whereof the undersigned being duly authorised thereto have signed this Agreement.



Done at Helsinki, this 28th day of October 2008, in duplicate in the English language.



For the Government of the Kingdom of Sweden



Anders Borg



For the States of Guernsey



Lyndon Trott



(Translation)



AGREEMENT BETWEEN the KINGDOM of the NETHERLANDS and GUERNSEY on the EXCHANGE of information in tax MATTERS



When the Government of the Kingdom of Sweden and the Government of Guernsey (the "parties") notes that the legislation in force in Guernsey already allows for cooperation and exchange of information in criminal cases,



the parties have agreed to conclude the following agreement, which entails obligations only for the parties:



Article 1



The scope of the agreement



The Parties shall assist each other with assistance through exchange of information likely to be relevant to the application and enforcement of the parties ' internal laws concerning taxes covered by this agreement, including the tasks that are likely to be relevant for the determination, assessment or collection, as well as for the collection or enforcement in respect of


taxes in respect of persons who are subject to such taxes or to the investigation or prosecution of tax cases in respect of such persons. The requested Party shall not be obliged to provide information which is neither held by its authorities nor in the possession of, or is available for persons under its jurisdiction. The rights of persons under the legislation of the requested Party or administrative practice remain applicable to the extent that they do not unduly prevent or delay an effective exchange of information.



Article 2



Taxes covered by the agreement



1. this Agreement shall apply to the following taxes which is imposed by the parties:



a) in Guernsey:



1) tax on income, and



2) tax on profit on the transfer of immovable property,



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 artistes etc.,



5) the municipal income tax,



6) capital yield tax on pension funds.



2. the agreement also applies to the taxes of the same kind after the signing of the agreement will be charged in addition to or in place of the currently outgoing taxes. If the parties agree, be applied also for the treasures of essentially similar kind after the signing of the agreement will be charged in addition to or in place of the currently outgoing taxes. The competent authority of each Party shall notify the other significant changes made to its legislation and that can affect that party's obligations under this agreement.



Article 3



Definitions



1. In this agreement: (a)) refers to the "Guernsey" Guernsey, Alderney and Herm, including the territorial sea adjacent to these islands in accordance with international law,



b) refers to "Sweden" the Kingdom of Sweden and the includes, when the expression is used in the geographic significance, Sweden's territory, territorial waters of Sweden and other maritime areas over which Sweden, in accordance with international law, exercises sovereign rights or jurisdiction;



(c)), the "company" or other legal entity that is treated for tax purposes as a legal person,



d) refers to the "competent authority", in Guernsey, the Administrator of Income Tax "or his representative and, in Sweden, the Minister of finance or his authorised representative or the authority which has been assigned to be a competent authority for the purposes of this agreement,



e) refers to the "criminal law" all criminal law is referred to as such in internal law, regardless of whether it is included in the tax law, criminal law or regulations;



f) refers to "these cases" tax matters involving intentional conduct committed before or after the entry into force of this agreement, which, according to the criminal law of the requesting party may be subject to criminal prosecution;



g) refers to "measures with a view to obtaining information" legislation and administrative measures or judicial measures which enable the requested party to obtain and provide the information requested,



(h)) refers to "information" means any fact, statement, document or Protocol regardless of the form,



in) refers to "personal" natural person, company, or other person, Association,



j) refers to companies whose shares are the object of general circulation "a company whose principal class of shares is listed on a recognised stock exchange provided its listed shares can be bought or sold by the public. Shares can be bought or sold "by the public" about the purchase or sale of shares is not implicitly or explicitly restricted to a limited group of investors;



k) refers to "principal class of shares" or the class that represents the majority of the votes in, and the value of the company,



l) refers to "public collective investment scheme" a system or a Fund in which the purchase, sale or redemption of shares or other rights, does not implicitly or explicitly restricted to a limited group of investors;



m) refers to "recognized stock exchange" such stock as the parties ' competent authorities agreed,



n) refer to the "requested Party" the Contracting Party that has been requested to provide or has provided information on request,



o) refers to the "requesting party" the contracting party who requests or receives the information from the requested Party;



p) refers to "tax" means any tax covered by this agreement.



2. When a party applies the agreement at a particular time is deemed, unless the context otherwise raises, each expression that is not defined in the agreement have the same meaning as the expression has at that time under the laws of that party and the importance of the term has under the applicable tax laws of that party take precedence over the significance of the expression have under other legislation of that party.



Article 4



Exchange of information on request



1. the competent authority of the requested Party shall, at the request of the requesting party may disclose information for the purposes set out in article 1. Such information shall be exchanged without regard to whether the requested Party needs the information for its own tax purposes or whether the conduct which is the subject of an investigation would have constituted an offence under the law of the requested party's laws if it took place within the territory of the requested Party. The competent authority of the requesting Party shall only request information pursuant to this article when it cannot obtain the information by other means, except in cases where the adoption of such measures would cause disproportionate hardship.



2. where the information available to the competent authority of the requested Party is not sufficient to respond to a request for information, the requested Party shall – notwithstanding that the requested Party may not need the information for its own tax purposes-in its sole discretion to take all relevant measures to obtain and provide the requested information to the requesting party.



3. If the competent authority of the requesting party specifically requests it, the competent authority of the requested party-to the extent that this is permitted under its internal legislation, provide information under this article in the form of admission of the witness reports and certified copies of documents.



4. Each Party shall ensure that it has the power, through its competent authority, on request, with regard to the conditions set out in article 1, to obtain and submit:



a) information held by banks, other financial institutions and other persons, including agents and trustees acting as representative or trustee,



(b)) 1) information on the legal and real ownership of companies, partnerships, trusts and other persons, including in the case of collective investment schemes, information on shares, units and other rights,



2) in the case of trusts, information on founders, managers, "protectors" and beneficiaries and, in the case of trusts, information on founders, members of the Board of Directors and beneficiaries.



This agreement imposes no obligation for a party to obtain or provide information on the ownership structure of companies whose shares are the object of general circulation or public collective investment schemes, unless such information can be obtained without incurring disproportionate difficulties.



5. any request for information shall be written and designed as fully as possible with the task of:



a) identity of the person who is the subject of the investigation or inquiry,



b) for what period of time the information is requested,



(c) the nature of the information requested) and the form in which the requesting party wishes the information to be provided,



(d)) the tax purpose for which the information is requested,



e) the reasons for believing that the information requested is likely to be relevant in the requesting party for the purposes of the application or enforcement of the tax laws in the case of the person referred to in subparagraph (a)) of this paragraph,



f) grounds for believing that the information requested is available in the requested Party or held by or accessible for a person within the territory of the requested Party;



g) as far as it is known, the name and address of the person who can be assumed to possess or control the information requested,



h) indicating that the request is in conformity with the laws and administrative practices of the requesting party to the competent authority of the requesting party-if the requested information was within the jurisdiction of that Contracting Party would be able to obtain the information under-law or customary administrative practices of the requesting party, and that the request is in conformity with this agreement;



I) stating that the requesting party has taken all measures to collect the information at its disposal in its own territory, but such measures would cause disproportionate hardship.



6. The competent authority of the requested Party, to the competent authority of the requesting Party shall acknowledge receipt of the request and shall endeavour to supply the information requested as soon as possible to the requesting party.



Article 5



Abroad-executed tax investigations




1. The requesting party may with reasonable notice, request that the requested Party allow representatives of the competent authority of the requesting party will be present in the requested party-to the extent that this is permitted under its domestic law-to hear natural persons and review the documents after the written consent of the persons concerned. The competent authority of the requesting Party shall notify the competent authority of the requested Party of the time and place of the planned meeting with the persons in question.



2. At the request of the competent authority of the requesting party, the competent authority of the requested Party allow representatives of the competent authority of the requesting party is present at the tax investigation on the territory of the requested Party.



3. Awarded a request pursuant to paragraph 2, the competent authority of the requested Contracting Party performing the investigation as soon as possible inform the competent authority of the requesting Party of the time and place of the investigation, the authority or person authorized to conduct the investigation, as well as the procedures and conditions as the requested Party has established for the conduct of the investigation. All decisions regarding the conduct of the investigation shall be taken by the requested contracting party carrying out the investigation.



Article 6



Opportunity to reject the request



1. The competent authority of the requested Party may refuse a request



(a)) when the request is not made in conformity with this agreement;



(b)) when the requesting party has not taken all the measures to obtain the information at its disposal in its own territory, except in cases where the adoption of such measures would cause disproportionate hardship, or



c) when the provision of the information requested would be contrary to the General considerations of public policy.



2. This agreement shall not entail an obligation on the requested party to disclose information covered by the obligation of professional secrecy in connection with legal advice or trade, business, industrial or professional secret or of a commercial secret or trade used the procedures, subject to that information should not be regarded as such a secret or such practices only because they are those listed in article 4, paragraph 4.



3. A request for information shall not be refused on the ground that the tax claim giving rise to the request is disputed.



4. the requested Party shall have no obligation to seek and provide information which the competent authority of the requesting party-if the requested information was within the jurisdiction of that party-can not obtain under its laws or customary practices.



5. the requested Party may refuse a request for information, if the information is requested by the requesting party in order to implement or give effect to a provision of the tax law, the requesting party or related requirements under the same conditions discriminate against a national of the requested Party in relation to a national of the requesting party.



Article 7



Privacy



1. All information submitted and received by the appropriate authorities of the Parties shall be kept secret.



2. Such information may be disclosed only to persons or authorities (including courts and administrative bodies) concerned with the purposes set out in article 1 and shall be used by such persons or authorities only for such purposes, including the processing of appeals.

For these purposes, the information may be divulged in public hearings or in judgements.



3. Such information shall not, without the express written consent of the competent authority of the requested Party, be used for purposes other than those specified in article 1.



4. Information provided to a requesting party under this agreement may not be disclosed to any other jurisdiction.



Article 8



Costs



Unless the competent authorities of the parties have agreed otherwise, the requested Party shall respond to the usual costs for assistance and the requesting party for the cost of assistance which cannot be regarded as usual (including costs of engaging external advisors in connection with process or for other purposes). The competent authorities shall consult from time to time in the case of this article, and in particular the competent authority of the requested Party shall consult in advance with the competent authority of the requesting Party of the costs to provide information in response to a specific request are expected to be high.



Article 9



Language



Request for assistance and response to such a request shall be drawn up in English.



Article 10



The procedure for the mutual agreement



1. where difficulties or doubts arise between the parties concerning the application or interpretation of this agreement, the competent authorities shall endeavour to settle the matter by mutual agreement.



2. in addition to the provisions of paragraph 1, the competent authorities of the parties may mutually agree on the procedures for the application of articles 4, 5 and 8.



3. Formal contacts, including requests for information, that is, by reason of the provisions of the agreement shall be made in writing directly to the competent authority of the other party at the address, which this second party Announces. All subsequent contact with respect to the request for information can be made either in writing or orally, depending on what is appropriate, between the competent authorities or their authorized representative.



Article 11



Date of entry into force



This agreement shall enter into force on the thirtieth day after the date on which the last of the written notification of the parties should leave-when the measures were taken as required under their respective legislation, has been provided. The agreement should be applied:



(a)) in these cases, as from that date, and



b) in all other matters covered in article 1, as from that date, however, only for the tax year that begins on 1 January of the year immediately following the calendar year in which the agreement enters into force, or later, or if the tax year is missing, on tax levied that day or later.



Article 12



Termination



1. this Agreement shall remain in force until terminated by one party.



2. Either party may terminate the agreement by a notice to that effect at least six months before the end of any calendar year. In the event of such termination, the agreement ceases to apply in respect of taxes which are levied for the fiscal year that begins on 1 January of the calendar year immediately following the expiry of the six-month period or later. Requests received before the date of termination shall be treated in accordance with the terms of this agreement.



3. If the contract is terminated, the Parties shall remain bound by the provisions of article 7 in respect of information received pursuant to this agreement.



In witness whereof the undersigned, being duly authorised, have signed this agreement.



Done at Helsinki on 28 October 2008, in duplicate in the English language.



For the Government of the Kingdom of Sweden



Anders Borg



For the Government of Guernsey



Lyndon Trott