section 1 of the agreement for the avoidance of double taxation with respect to

taxes on income and on capital as Denmark, Faroe Islands,

Finland, Iceland, Norway and Sweden signed on 23

September 1996, together with the protocol attached

to the agreement and which are part of this, in the wording of these

have by the Protocol amending the agreement signed

on 4 april 2008, apply that law in this country. The agreement's

provision in article 3, paragraph 1 (a) the expression "Finland" does not

include the Åland Islands, in the case of the Finnish

municipal tax shall not apply.



Agreement and Protocol is drawn up in the Danish, Faroese,

Finnish, Icelandic, Norwegian and Swedish languages. In Swedish

the language has been issued two texts, one for Finland and for

Sweden. All texts are equally authentic. The for Sweden

issued the text set out in annex 1 to this Act.



The agreement between Sweden and Denmark on the taxation of

employees aboard ferries and trains in regular service between

Denmark and Sweden signed on 30 september 1999

to be valid as law in this country. The agreement is drafted in Danish

and Swedish languages. It is clear from the text issued for Sweden

of annex 2 to this Act.



The agreement between Sweden and Norway signed on 22

October 2002 and which contains specific provisions for the

avoidance of double taxation in connection with the construction, maintenance and

operation of the border bridge that is part of the new Svinesund connection

to be valid as law in this country. The agreement is drawn up in Swedish

and Norwegian languages. It is clear from the text of Sweden issued

Annex 3 to this law.



The agreement between Sweden and Denmark on certain tax matters

signed on 29 September 2003 to apply that law here in

the country. The agreement is written in Swedish and Danish languages. The

for Sweden, issued the text set out in annex 4 to this

team. Law (2008:653).



section 2 of the tax rules of the agreement shall apply only in so far as

These involve restriction of the tax liability in Sweden that would otherwise

would exist.



3 repealed by law (2011:1382).



paragraph 4 for the purposes of the provisions of article 31, paragraph 5 of the agreement

the following shall apply.



The expression "less interruption" referred to suspend service in

the rules state that lasts



1) not more than 18 months per child due to parental leave,



2) a total of not more than 12 months during a period of 36 months for

everything else break than break due to such a disease referred to in

third subparagraph (leave of absence, unemployment etc.).



If a person is absent from work due to illness

This does not mean that he does not continue to meet the

conditions laid down in paragraphs 2 and 3 of section VII of the Protocol

paragraphs 2 and 3, respectively, in point VIII of the Protocol in the Protocol

to the agreement of 12 september 1989 between the Nordic countries

the avoidance of double taxation with respect to taxes on income and on

Fortune provided him throughout the nursing period

retain their employment.



A period during which a person carries on his enduring personal work in

the State of residence is not considered to be a "short break".



The provisions in paragraphs 4-6 of section VII of the Protocol respectively

paragraphs 4-6 of Protocol paragraph VIII of the above Protocol shall

apply for the purposes of paragraphs 2 and 3 of section VII of the Protocol

paragraphs 2 and 3, respectively, in point VIII of the Protocol.



The provisions in paragraphs 2 and 3 of section VII of the Protocol respectively

paragraphs 2 and 3 of section VIII of the Protocol to the above-mentioned Protocol

does not apply in the case of employment with the same employer

during a continuous period of less than six months.



paragraph 5 of the Protocol On the application of the provisions of paragraph II of

Protocol to the agreement the following shall apply. The provisions on

tunnel connection also applies for the artificial peninsula in Denmark

to the extent this is landscaped or maintained by or for

The Oresund Consortium. What is provided on the bridge over the sound comes

also for the pay station in Sweden to the part that is being built,

maintained or operated by or for the Oresund Consortium.



paragraph 6 of article 31 paragraph 3 of the agreement shall be applied

without the limitation in time resulting from the second

meaning. Article 26, paragraph 2 of the agreement shall not apply in the case

Article 31, paragraph 3 of the agreement shall apply.



As provided for in the first subparagraph shall, irrespective of

the provisions of annex 2 to this Act, also apply to

income that a person resident in Sweden receives for work

aboard the Danish ship in international ferry service between

Sweden and Denmark. Law (2007:767).



section 7 of the provisions in the Protocol section VII (a) of paragraph 2 of

Protocol to the agreement of 23 April 1996,

applied. Law (2008:653).



Transitional provisions



1996:1512



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



2. This Act shall apply



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following the

years when the Act comes into force or later,



(b)) in respect of other taxes on income, to taxes that are determined for

tax year that begins on 1 January of the calendar year following

immediately following the year in which the law comes into force or later,



(c)) in respect of tax on wealth, on the fortune of the tax

deleted due to tax assessment second calendar year after the year in which the law

enters into force, or later.



3. Through law repeals Act (1989:933) of double taxation agreements

between the Nordic countries.



The repealed Act shall, however, continue to apply



(a)) in respect of taxes on income at source of content, as

acquired before 1 January of the calendar year immediately following

the year in which the law comes into force,



(b)) in respect of other taxes on income, to taxes that are determined for

tax years beginning before 1 January of the calendar year

immediately after the year in which the law comes into force,



(c)) in respect of tax on wealth, on the fortune of the tax

deleted because of taxation the first calendar year following the year in which the law

enters into force or before.



The repealed Act shall also apply in the cases referred to in article

31 paragraph 5 of the agreement in so far as it relates to paragraphs 2-6 of Protocol paragraph VII

and paragraphs 2-6 of Protocol paragraph VIII of the Protocol to the agreement

on 12 september 1989 between the Nordic countries in order to avoid

double taxation with respect to taxes on income and on capital.



4. Has been suspended by the law (2007:767).



1997:658



The Government states that the Act (1996:1512) if

double taxation agreement between the Nordic countries shall take

in force on 31 december 1997, then the Regulation (1989:957) if

double taxation agreement between the Nordic countries

cease to apply.



The agreement entered into force on 11 May 1997.



1999:639



This law shall enter into force on the day the Government determines and

apply in the case of the Åland Islands from the time of the agreement

referred to in paragraph 1, second subparagraph applied and otherwise on

income acquired on January 1, which follows directly after the

the year in which the law comes into force or later. Law (1999:1184).



1999:999



This law shall enter into force on the day the Government determines and

apply to income that is acquired on January 1, as follows

immediately following the year in which the law comes into force or later.



2002:982



This law shall enter into force on the day the Government determines and

apply to taxes on income and on capital as defined

for each tax year that begins on 1 January of the

calendar year immediately following the year in which the law comes into

force or later.



2004:639



This law shall enter into force on 1 August 2004 and will apply

with regard to the



(a)), article 2, article 3, article 5, paragraphs 2 and 3, as well as

Article 6 of the agreement in annex 4 tax included

for tax years beginning on 1 January 2004 or

later, and



(b)) other articles and items of the agreement in annex IV of taxes

for tax years beginning on 1 January 2005

or later.



2008:653



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



2. this law shall apply to the taxes levied for

tax year that begins on 1 January of the calendar year in which

immediately after the year in which the law comes into force or

later.



Annex 1



Agreement



among the Nordic countries to avoid double taxation

with respect to taxes on income and on capital



The Danish Government together with the Faroe Islands and

The Finnish, Icelandic, Norwegian and Swedish Governments,



Desiring to conclude an agreement for the avoidance of double taxation

with respect to taxes on income and on capital,



Noting that in the case of operation even in the Faroe Islands

relation to the rest of the matters covered by

This agreement belongs to the Faroese self-government skills,



have agreed as follows:



Article 1



Persons covered by the agreement



This agreement shall apply to persons who are resident in one or

several of the Contracting States.



Article 2



Taxes covered by the agreement



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

wealth that accrues to everyone of the Contracting

States, its political underavdelningars or local

authorities, irrespective of the manner in which taxes

be taken out.



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

taxes based on income or wealth in its entirety

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 currently outgoing taxes to which the agreement

applied is



(a)) in Denmark



1) the income tax to the State,



2) the municipal income tax,



3) on amtskommunala income tax, and



4) taxes according to the kolväteskattelagen,



(in the following referred to as "Danish tax");



(b)) in the Faroe Islands



1) tax to the country's coffers,



2) tax to the municipalities,



3) the church tax;



4) dividend tax,



5) royalties tax,



6) interest tax, and



7) taxes according to the kolväteskattelagen,



(in the following referred to as "the Faroese tax");



c) in Finland



1) the State income tax,



2) income tax for corporations,



3) municipal tax,



4) the church tax;



5) the withholding tax on interest income,



6) the withholding tax for limited taxpayer, and



7) State property tax,



(in the following referred to as "Finnish tax");



d) in Iceland



1) the income tax to the State,



2) the Special income tax to the State,



3) the municipal income tax,



4) wealth tax to the State,



5) the special wealth tax to the State, and



6) income and wealth tax for financial institutions,



(in the following referred to as "Icelandic tax");



e) in Norway



1) income and wealth tax to the State,



2) income and wealth tax to the municipalities,



3) income tax to counties,



4) the common tax to tax distribution fund,



5) taxes according to the petroleum tax law, and



6) fee to the State on remuneration to non-resident

artists,



(in the following referred to as "Norwegian tax");



f) in Sweden



1) state income tax, including the ship's treasure

and



coupon tax,



2) the Special income tax for non-residents,



3) the Special income tax for non-resident artists

et al.,



4) expansion Fund tax,



5) the municipal income tax, and



6) State property tax,



(in the following referred to as "Swedish tax").



4. the agreement shall 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 currently outgoing

the taxes. In the case of Denmark and the Faroe Islands applied the agreement

In addition to such general tax on wealth as Denmark

Faroe Islands, respectively, may be put in place after the signing

of the agreement. The competent authorities of the Contracting

States shall notify each other of the essential changes that

made in the respective tax laws.



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) "Contracting State" refers to Denmark, Finland, Iceland,

Norway and Sweden; the term also includes it in the Danish

Empire self-governing Faroe Islands folk community; to the extent

the provisions of the agreement only concerns the relationship between

Denmark and the Faroe Islands are used the expressions "a part of the Kingdom" and

"the other part of the Empire", as the context requires;



the term also covers any outside the State

territorial waters situated area in which this State under

their legislation and in accordance with international law has

rights with respect to the exploration and exploitation of the

natural resources on the seabed or its subsoil;



"Denmark" does not include the Faroe Islands and Greenland; "Finland"

does not include the Åland Islands, in the case of the Finnish

municipal tax; "Norway" does not include Svalbard (with which

also includes bear Island), Jan Mayen and the Norwegian territories

("biland") outside of Europe;



b) "person" includes natural persons, companies and

personal association;



c) "company" refers to the legal person or other that at

taxes are treated as entity;



(d)) "Association" refers to association not

taxed as independently taxable entity;



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

Contracting State "refers to the business carried on by any person with

resident in one Contracting State, the respective companies

carried on by a resident of the other Contracting State;



f) "real property" has the same meaning as the expression has, in

the law of the Contracting State in which the property is

located; However, the term always includes accessories for fixed

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

buildings, rights to which the provisions of private law

If immovable property apply, usufruct of immovable property and

the right of changing or fixed remuneration for the use

of, or the right to use mineral occurrence, source or other

natural resource;



g) "national" refers to the natural person who has the citizenship of

a Contracting State; natural person who is a Danish citizen

and who is resident in the Faroe Islands, according to the law if such is deemed

have citizenship only on the Faroe Islands; the term also refers to the

company or personal Association incorporated under the

laws in force in a Contracting State;



h) "international traffic '' refers to transport by ship or

aircraft, except when the ship or aircraft is used

exclusively between places in a Contracting State;



in) "community of interest" refers to cases where an undertaking directly or

indirectly involved in the management or control of another

enterprises or own significant part in this other business capital

or if the same persons directly or indirectly participating in

management or control of both enterprises or own

essential part of these companies ' capital;



j) "competent authority" refers to



1) in Denmark: tax Minister,



2) to Faroe Islands: country's Governor for financial matters,



3) in Finland: the Ministry of finance,



4) in Iceland: the Minister of finance,



5) in Norway: finance-and tariff Minister,



6) in Sweden: the Minister of finance,



or the authorized representative or the authority in each of the

those States for which any of the above or other

instructs to deal with issues concerning the agreement.



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 reference to the expression "person

resident in one Contracting State "person under

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

domicile, residence, place of management or any other

similar circumstances, and also includes that State, its

political subdivisions, local authorities and

public-sector institutions. The expression



a) does not include a person who is liable to tax in that State

only on income from sources in that State or of

wealth located there, and



b) includes personal association and estate only to the

part of their income and wealth are taken to taxation in

This State in the same way as income acquired

each Fortune held by resident there.



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

resident in several 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 residence in several States, he is considered 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 is not in any State has a

residence permanently at his disposal, he is deemed to

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



(c)) if he usually resides in multiple States, or if he does 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 several States, or if he is not

nationals of any of them, the competent authorities of

relevant Contracting States in question by mutual

agreement.



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

natural person domiciled in several Contracting States, shall be considered to

the person in question be a resident only of the State in which it has its

effective management.



Article 5



Permanent establishment



1. for the purposes of this agreement reference to the expression "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. A building, facility, installation, or

the Assembly project, or the activity of planning,

monitoring, counseling or other auxiliary staff effort in

associated with such a project, constitutes a permanent establishment but only

If the project or activity is taking place more than 12 months in a

Contracting State.



4. for the purposes of calculating the period referred to in paragraph 3 shall be deemed to

activities, carried out by a company that has

Community of interest with other enterprises, undertaken by the company

with which it is associated if the activities in


materially are of the same nature as the activities it

the latter company and both companies ' activities

relating to the same project.



5. 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 to) stock in trade solely

for storage, exhibition or distribution,



(c) holding of a company belonging to) stock in trade solely

for working or processing by other company,



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) holding of fixed place of business

exclusively for combining activities listed in punktema

a)-(e)), provided that all the activities

conducted at the permanent place of business in

because of this combination is of a preparatory or auxiliary

art.



6. If the person who not is such independent representative on

what point 7 apply, works for a company, as well as in a

Contracting State, and which are regularly using power of Attorney

to conclude agreements in the company name, this company-without

by way of derogation from paragraphs 1 and 2 have fixed

place of business in that State in respect of each activity as this

person engaged in for the company. However, this does not apply, if the

activity which that person carries is limited to such

as indicated in paragraph 5 and that-if it was done from a

fixed place of business-would not make

This fixed place of business to the firm

establishment, in accordance with the provisions of that paragraph.



7. 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 representative, if such

in doing so, the person is engaged in his usual business.



8. the fact that a company resident in a

Contracting State controls or is controlled by a

company resident in the other Contracting State or a company

doing business in the other Contracting State

(either from a permanent establishment or otherwise),

not in and of itself to constitute either company a permanent establishment

for the other.



Article 6



Income from immovable property



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

acquires immovable property (including income from agriculture

and forestry) situated in the other Contracting State,

be taxed in that other State.



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

through immediate utilization, through rental or other

use of immovable property.



3. where the ownership of shares or other participations in companies, whose

main purpose is to hold real property, are eligible

the holder of the shares or units that use the company

relating to immovable property, get income, acquired by

immediate utilization, through rental or other use of

such access rights, be taxed in the Contracting State in which the

the property is situated.



4. the provisions of paragraphs 1 and 2 shall also apply to

income from immovable property belonging to the company and on the income of

immovable property used for the independent professional practice.



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 located

permanent establishment. If the enterprise carries on business in such a way,

company's income may be taxed in that other State, but only

so much of them 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, attributed,

except where the provisions of paragraph 3 shall give rise to another, in each of the

the relevant Contracting States to the permanent establishment

the income that it can be assumed that the establishment would have

acquired, if it were a stand-alone company, which conducted

activities of the same or a similar nature in the same or

similar conditions and independently completed the business with it

undertaking to which the establishment belongs.



3. In determining permanent establishment income deduction is allowed

for expenses incurred for the permanent establishment, including

including expenditure for management and General

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

permanent establishment is situated or elsewhere.



4. To the extent that the income attributable to the permanent establishment used in

a Contracting State shall be determined on the basis of a distribution

of the company's entire income on the different parts of the company,

do not prevent the provisions of paragraph 2 of this

Contracting State taxable income is determined by

such a procedure. The allocation method used shall be

be such that the result is consistent with the principles of

This article.



5. 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.



6. 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.



7. 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, as a person resident in one Contracting State

acquires through use of ships or aircraft in

international traffic, be taxable only in that State.



2. income, as a resident of a Contracting State

acquires through the use, maintenance or rental of

containers (including trailers and other equipment for

the transport of containers) used for the transport of goods

or goods, be taxable only in that State except in the container

used exclusively between places in the other Contracting State.



3. the provisions of paragraphs 1 and 2 shall also apply to

income that are acquired through participation in a pool, a joint

business or an international operating agency.



Article 9



Related companies



1. In cases where the



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

participate in the management or control of an undertaking in another

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 a business in the other Contracting State or own part i

These corporate capital,



observed the following.



If between businesses in terms of trade relations or

financial relations agreed upon or prescribed conditions, as

differ from those which would have been agreed between each other

independent company, receives all the income, that without such conditions

would have been one company but who, because of

the terms in question did not come about this company, be included in the

This company's income and taxed accordingly.



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

in this State do-and accordingly, taxes

-income, for which a company in another Contracting State

be taxed in that other State, and it thus included

income is such as would have been the company in the

first State if the conditions agreed between the companies

had been those which would have been agreed between each other

independent companies, the other State conduct due

adjustment of the amount of tax levied on income which, if

that other State considers the adjustment justified both in

principle in respect of the amount. When such adjustments are observed

the other provisions of this agreement and the competent authorities

in the relevant Contracting States in talks if necessary with

each other.



Article 10



Dividend



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

to a resident of the other Contracting State may

be taxed in that other State.



2. In cases where the actual holders of the benefit of dividends with

resident in one Contracting State has a permanent establishment or

permanent device in another Contracting State

He is a resident and the proportion due to the dividend payment

paid owns real connection with business carried on from the

permanent establishment and independent professional activity as

be exercised from the permanent device, may, notwithstanding

the provisions of paragraphs 1 and 3, dividends from companies with

resident in one Contracting State to such genuine holders

taxation in accordance with the provisions of article 7 and

Article 14 in the Contracting State in which the permanent establishment

and the permanent devices are available.



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

to a resident of the other Contracting State may

also 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 privilege of


the dividend is a resident of the other Contracting

the State, the tax so charged shall not exceed 15

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

However, be exempt from taxation in the first-mentioned

State if the beneficial owner of the benefit of the dividend

is a company (other than a personal association and estate)

which directly owns at least 10 per cent of the company's

capital. In cases where a company resident in a Contracting

State owns a share in a paying company in another

Contracting State, one or more

personal associations, is considered for the purposes of this paragraph,

the company directly owns share of the paying company. The company's

proportion of the paying company due to such content should

be considered equivalent to the share that the company owns in the paying

the company, through personal association or

personal associations.



4. Notwithstanding the provisions of paragraph 3, the Icelandic tax

on the dividend to be increased to a maximum of 15% to the extent that such

dividends, deducted from income by the paying company at

determination of the Icelandic tax.



5. the provisions of paragraphs 3 and 4 shall not affect the company's

taxation on the profits out of which the dividends are paid.



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

shares, participation or other rights, not being

Receivables, with the right to share in profits and other income

from companies who, under the law of the State where the

distributing company is resident for tax purposes shall be treated in the

the same way as income from shares. The term dividend

of course, even income from an order giving rise to the right to share

in profits to the extent that, under the law of the

Contracting State from which it is derived form such income.



7. Notwithstanding the provisions of paragraphs 3 and 4, the

competent authorities of the Contracting States

agree that the dividend accruing to the agreement

named institution with generally beneficial or otherwise

public purposes, which under the law of the

Contracting State in which the institution is resident is exempt

from tax on dividends, in the other Contracting State may be

exemption from tax on dividends from companies in that other State.



8. If the company resident in one Contracting State acquires

income from the other Contracting State, that other State

not taxing dividend that the company pays, except to the extent

the dividend is paid to a resident of the other State

or to the extent that the portion due to the dividend payment

paid owns truly connected with a permanent establishment or

permanent device in that other State, nor on

the company's undistributed profits to a tax payable on

the company's undistributed profits, even if the delivery or the

undistributed profit consists wholly or partly of income

raised 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 in question is the

beneficial holder of the privilege of the interest.



2. In cases where the actual holders of the benefit of the interest rate established

of a Contracting State has a permanent establishment or

permanent device in another Contracting State

He is a resident and the claim in respect of which the interest is paid is the owner

effectively connected with the business carried on by the Permanent

establishment and independent professional activity exercised

from the permanent device, may, notwithstanding

the provisions of paragraph 1, interest arising from a

Contracting State and paid to such real

holders are taxed in accordance with the provisions of article 7

and article 14 in the Contracting State in which the Permanent

establishment and permanent devices are available.



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

each kind of claim that are not dividend under article 10

paragraph 6, whether secured by mortgage

property or not. The term refers to the particular income by

securities, issued by the 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.



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

the beneficial owner or between both of them and any other person

the amount of the interest, having regard to the debt for which interest rate

paid, exceeds the amount which would have been agreed between

the payer and the beneficial owner of such relationships

not exist, the provisions of this article shall apply only

the latter amount. In such case the excess is taxed

amounts in accordance with the legislation of each of the relevant

Contracting States, subject to compliance with the other provisions

in this agreement.



Article 12



Royalty



1. Royalty, as derived 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 in question is the

beneficial holder of the privilege of royalty.



2. In cases where the actual holders of the benefit of royalties with

resident in one Contracting State has a permanent establishment or

permanent device in another Contracting State

He is a resident, and the right or property in respect of

the royalty payable owns real connection with business as

carried out by the permanent establishment and independent

professional activity exercised by the permanent device,

may, notwithstanding the provisions of paragraph 1, royalty

derived from a Contracting State and paid to such

genuine holders are taxed in accordance with the provisions of

Article 7 and article 14 in the Contracting State in which the

the permanent establishment and the permanent devices

There is.



3. 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

and tapes for radio and television broadcasting), any patent,

trademark, design or model, plan, secret formula or

secret manufacturing process or for information about

experience knowledge of industrial, commercial or scientific

nature.



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

the beneficial owner or between both of them and any other person

royalty amount, taking into account the utilization, the right

or the enlightenment for which royalties are payable, the excess

the amount which would have been agreed between the payer and the

beneficial holder of such relationships do not exist,

the provisions of this article shall apply only to the latter

amount. In such case, the excess amount is taxed according to the

the legislation of each of the Contracting States concerned

subject to 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 immovable property

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

other State.



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

acquires from the alienation of shares or other interest in the

companies whose main purpose is to hold real estate and

whose assets (before deduction of liabilities) directly or indirectly

For more than 75 per cent consists of immovable property situated in the

any other Contracting State, may be taxed in that other State.



3. Gains from the alienation of movable property forming part

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

a Contracting State has in the other Contracting State, or

of movable property, attributable to a permanent device to

exercise independent professional activities, such as physical person with

resident of a Contracting State has in the other Contracting

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

the alienation of such a permanent establishment (alone

or together with the whole enterprise) or of such a

permanent device.



4. Profit, as a person resident in one 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.



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

acquires from the alienation of containers (in that

including trailers and other equipment for the transport of

containers) used for the transport of goods or merchandise,

be taxable only in that State except where the container is used

solely between places in the other Contracting State.



6. Gains from the alienation of property other than that

referred to in paragraphs 1 to 5 shall be taxable only in the Contracting

State of which the alienator is a resident.



7. Gains from the alienation of shares or other share

or right of company or personal association

is acquired by an individual who has been resident in a

Contracting State, a resident of the other Contracting

State may-notwithstanding the provisions of paragraph 6-taxed

in the first-mentioned Contracting State if the transfer of

the share, the share or right is made at any time during the

the 10 years immediately after the person ceased to


be domiciled in the first State. The first State may

However, only tax the capital gain incurred before the

physical person got established in the other Contracting

State. With the right person in the company or association purposes

for the purposes of this paragraph, right or other access

that under the legislation of the first State at

taxation of profit due to

the transfer of the share in the company or person Association.



Article 14



Independent professional activities



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

State acquires through the exercise of profession or other

independent operations, shall be taxable only in that State.

the income may be taxed in the other Contracting State,

If



(a)) he's in that other State has a permanent device which

regularly available to him in order to exercise

but only so much of the income as is

due to this permanent device, or



(b)), he resides in that other State during the time period or

time periods that in total exceed 183 days during a

twelve-month period commencing or ending in the

the tax year in question, but only so much of the income

that is attributable to the activity that has been practiced in this second

State during this time period or these time periods.



2. The expression "liberal profession" includes especially independent

scientific, literary and artistic activities,

educational and teaching activities and such

independent operations, as a doctor, lawyer, engineer,

Architect, dentist and an accountant.



Article 15



Single service



1. the provisions of articles 16, 18, 19, 20 and 21

causing the other, taxable wages and other similar remuneration,

as a resident of a Contracting State carries on the basis

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

in the other Contracting State, If the work is done in this second

State, the remuneration 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

receipt for work performed in the other Contracting State,

only in the first-mentioned State if



a) recipient resides in that 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 establishment or

permanent device which the employer has in that other

State, as well as



d) issue is not about labour hire.



3. Notwithstanding the preceding provisions of this article,

income from work performed on board the Danish, Faroese,

Finnish, Icelandic, Norwegian or Swedish ships in international

traffic, be taxed in the Contracting State whose nationality

the ship has; for the purposes of this provision, on an equal footing

foreign ships, chartered on a bareboat basis of

a resident of a Contracting State, with Danish,

Faroese, Finnish, Icelandic, Norwegian and Swedish ships.



4. Notwithstanding the preceding provisions of this article

taxable income from work, which is carried out on board



a) aircraft, only in the Contracting State in which the

acquires work income is domiciled,



b) fishing, sealing or whaling vessel, only in the

Contracting State in which the person acquiring the earned income has

resident, even when the income of the work in the form of specific

lottery ticket or share of the profits of fishing, sealing or

the whaling business.



Article 16



Directors ' fees



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

resident in one Contracting State receives as a member of the

Board or other similar bodies in companies established in other

Contracting State, may be taxed in that other State.



Article 17



Artists and athletes



1. Notwithstanding the provisions of articles 14 and 15,

income, as a resident of a Contracting State

acquires by their personal activities in 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. In cases where the income through activities such as artist or

athletes engaged in that capacity, not become the property of

artist or sportutövaren yourself without the other person, this

income, notwithstanding the provisions of articles 7, 14 and

15, 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

through activities such as artist or sportsmen and women resident in a

Contracting State, carries on in the other Contracting State in case

then the visit to that other State is mainly financed by

public funds in the first State. In such a case

income is taxed only in the first-mentioned State.



Article 18



Pension, etc.



1. Pensions and annuities paid by a Contracting State

and payment of a Contracting State in accordance with

social legislation in this State to any person resident in

other Contracting State may be taxed in the first-mentioned

State.



2. Notwithstanding the other provisions of this Agreement shall

child support, which a resident of a Contracting

State pay to the spouse or former spouse or to children

a resident of the other Contracting State, shall be exempt from

taxation in the other State if the contribution would have

exempt from tax in that State if

the receiver had been domiciled there.



3. The term "annuity" means a fixed amount

payable to an individual periodically at specified times

during the person's lifetime, or during a specified or ascertainable

period of time and that is because of the obligation to

enforce these payments as compensation for however

fully corresponding consideration in money or money value.



Article 19



Public service



1. Wages and other similar remuneration (with the exception of

pension), paid by a Contracting State, one of its

political subdivision, local authority or

public-sector institutions to the individual due to

work performed in this State, section, Government

or institutional service, shall be taxable only in that State.



2. where salary or other similar remuneration referred to in paragraph 1

accrue to the recipient for the work which they perform in different

Contracting State other than that from which the salary or compensation

paid, taxed salary or compensation, however, only in

the State in which the work is performed, if the recipient is the person with the

a resident of this State and



a) is a national of that State, or



(b)) was not allowed to live in this State solely for the purpose of performing

the work.



3. the provisions of articles 15, 16 and 17 shall apply to salaries

and other similar remuneration paid for work

performed in connection with business carried on by a

Contracting State, its political subdivisions,

local authorities or public law institutions.



Article 20



Students and trainees



Person resident in one Contracting State exclusively for



a) studies at the educational institution in this State, if the studies are of

such that the aid of public funds can be obtained in

that State, or



b) business, fisheries, industry, agriculture or

forestry practice in this State;



and that has, or immediately prior to their habitual residence in

other Contracting State, is not taxed in the first-mentioned

the State for the amount that he receives from outside this

State for their livelihoods, their education or training.



Article 21



Activities in connection with preliminary surveys, exploration

or use of carbon hydrogen occurrence



1. Notwithstanding the other provisions of this agreement, with

except for the provisions in article 8, shall be applied

the provisions of this article in cases where the resident of the

a Contracting State carries on business in connection with

Preparatory investigation, exploration or exploitation of the

carbon hydrogen discoveries located in a Contracting State.



2. a) Person resident in one Contracting State, which is outside the

coast in the other Contracting State carrying on business as

referred to in paragraph 1, shall be deemed to operate from fixed

establishment or permanent device in that other State.



b) If such person carries out its activities in the exploration

or the mining area which stretches from a place outside

coast in that other State and the State's land area and

activities are not exclusively carried out on the land, own

paragraph (a)) the corresponding application.



c) activities, consisting of the construction or installation of

pipeline for the transport of crude hydrocarbons, or

construction work in direct connection with such activities, are considered to

undertaken from a permanent establishment in that other State in respect

If such activity is going on in the country, when operations are included in

a project that extends from a location off the coast of

This State and this State's land area.



3. the provisions of paragraph 2 shall not apply if the activity

during the period or periods totalling not

more than 30 days in any 12-month period.



4. for the purposes of calculating the period referred to in paragraph 3 shall be deemed to

activities, carried out by a company that has

Community of interest with other enterprises, undertaken by the company


with which it is associated if the activities in

materially are of the same nature as the activities it

the latter company and both companies ' activities

relating to the same project.



5. income, as a company of a Contracting State acquires at

because of transportation of personnel or equipment of ships or

aircraft to or inside the area referred to in punktema (2) (a))

and 2 b) of the other Contracting State in which the business

carried out in the course of preliminary investigation, exploration

or use of carbon hydrogen bodies or due to operational

of tugs, supply vessels or other auxiliary vessels in

related to such activities, shall be taxable only in the

first State.



6. the provisions of article 13, paragraph 4, and article 23, paragraph 3

apply to gains from the alienation of ships, boats

or aircraft referred to in paragraph 5 and fortune

consisting of such ships, boats or aircraft.



7. Notwithstanding the other provisions of the agreement, the following

in respect of the taxation of salaries and other similar compensation

as a resident of a Contracting State carries on the basis

of work which is performed in the other Contracting State for

employers carrying out an activity referred to in

paragraphs 1 and 2:



a) except where the provisions of paragraphs b)-d) causing the other,

receive such salary or compensation is taxed in the other State,

but only if the work going on there during the time period or

time periods that in total exceed 30 days during a

12-month period.



b) Such salary or remuneration shall be taxable only in the

first-mentioned Contracting State if



1) work in connection with the use of carbon hydrogen occurrence

located on the middle line between Contracting States

or between a Contracting State and any other State,



2) agreement exists between these States on the common

use of occurrences, and



3) exploitation takes place simultaneously on both sides of the midline.



The provisions of this paragraph apply only after

agreement thereon between the competent authorities of the

Contracting States.



c) If work is carried out on board ship or boat referred to in

paragraph 5, such salary or remuneration are taxed in the

Contracting State in which the person using the ship or

the boat is a resident.



d) If the work is carried out on board vessels referred to in paragraph 5,

such salary or compensation is taxed only in the

Contracting State in which the company is domiciled.



8. the resident of a Contracting State who carries on

operations off the coast of another Contracting State is

exempt from taxation in that other State for profit

This person is considered to have acquired due to the transfer of

movable drilling platform facility or to area hotels

outside that other State. A profit in this point of course

amount by which the fair market value at the time of

the transfer exceeds the residual value at the time of

the addition of any depreciation.



9. Profit as a resident of a Contracting State

acquires the alienation of



a) right to preliminary investigation, exploration or

utilization of carbon hydrogen occurrences in the other Contracting State,

including the right to share in or benefit of such

occurrences, or



b) shares or other participations in companies, the value of which is wholly or

essentially, directly or indirectly, related to

such right,



may be taxed in that other State.



Article 22



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 if the recipient

domiciled in a Contracting State and has a permanent establishment

or permanent device in the other Contracting State and

the right or property in respect of which the income is paid

owns real connection with business carried on by the Permanent

establishment and independent professional activity exercised

from the device permanently. In such a case be applied

the provisions of article 7 or article 14. Included in the fixed

establishment or permanent device real estate

However, income taxation of such property pursuant

the provisions of article 6 paragraphs 1, 2 and 4.



Article 23



Fortune



1. Fortune consisting of immovable property as resident

in a Contracting State and situated in the other

Contracting State may be taxed in that other State.



2. Assets consisting of shares or other interest in company

whose main purpose is to hold real estate and whose

assets (before deduction of liabilities) directly or indirectly to

more than 75 percent consists of immovable property situated in a

Contracting State, may be taxed in that State.



3. wealth consisting of ships or aircraft used

in international traffic and by movable property that is owed

to the use of such ships or aircraft, and owned

the resident of a Contracting State, shall be taxable

only in that State.



4. wealth consisting of containers (including

trailer and other equipment for the transport of containers)

used for the transport of goods or merchandise, and owned by

person resident in one Contracting State, be taxable only in

This State, except where the container is used exclusively between

places in the other Contracting State.



5. All other property, regardless of where this is located, which

person resident in one Contracting State, be taxable

only in that State.



6. Notwithstanding the provisions of paragraph 5 shall be

Fortune consisting of movable property forming part of the

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

Contracting State has in the other Contracting State, or by

movable property, attributable to a permanent device to

exercise independent professional activities, such as physical person with

resident of a Contracting State has in the other Contracting

State, be taxed in that other State.



7. the provisions of paragraphs 1 to 6 shall apply in a Contracting

State only in relation to the other Contracting State in which

take out general tax on wealth.



Article 24



Estate



Income or asset that is taxed at estate established in

a Contracting State shall not be taxed in Inheritors

a resident of the other Contracting State.



Article 25



The Elimination of double taxation



1. Denmark



a) where a resident of Denmark receives income which, in accordance with

the provisions of this agreement, may be taxed in the other

Contracting State, Denmark, unless the provisions

in paragraph b) or c) give rise to the other, from that person's Danish

income tax set off an amount equal to the income tax

paid in that other State.



Settlement amount shall not, however, exceed that part of the

the Danish income tax, calculated without such a settlement, which

attributable to the income which may be taxed in that other State.



b) where a resident of Denmark receives income which, in accordance with

the provisions of this Agreement shall be taxable only in the other

Contracting State, Denmark may include this income in

the taxable amount but to put down the Danish tax

on income through deduction of that part of the income tax

charged on the income derived from that other State.



(c)) where a resident of Denmark receives income referred to

in article 15, paragraph 1 or article 21, paragraph 7 (a)), Denmark

the inclusion in income of taxable amount but to put down

the Danish tax on income by subtracting the portion of

income tax attributable to the income derived from this

other State.



2. the Faroe Islands



a) where a resident of the Faroe Islands receives income that

in accordance with the provisions of this agreement may be taxed in the other

Contracting State, the Faroe Islands, unless the provisions

in paragraph b) or c) give rise to the other, from that person's

Faroese income tax set off an amount equal to the

income tax paid in that other State.



Settlement amount shall not, however, exceed that part of the

the Faroese income tax, calculated without such a settlement, which

attributable to the income which may be taxed in that other State.



b) where a resident of the Faroe Islands receives income that

in accordance with the provisions of this Agreement shall be taxable only in the other

Contracting State, may include income in the Faroe Islands

the taxable amount but to put down the Faroese treasure

on income through deduction of that part of the income tax

charged on the income derived from that other State.



c) if the person on the Faroe Islands from other Contracting

State receives income of individual service referred to in article 15

paragraph 1 or article 21, paragraph 7 (a)) and that according to these

points may be taxed in that other Contracting State, may

Faroe Islands include income in the tax base, but shall

reduce the income tax by deduction at the Faroese with

that part of the income tax levied on the income derived

from that other State.



3. Finland



a) where a resident of Finland receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Finland, unless

the provisions of paragraph b), c) or (d)) gives rise to different,

subject to the provisions of Finnish law (also in

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

general principle referred to here are affected),




1) from this person's Finnish income tax set off an amount

equivalent to the income tax paid in that other State

under the law of that other State and in conformity

with the agreement, calculated on the same income as that on which the

Finnish tax is calculated;



2) from this person's Finnish property tax set off a

amount equal to the capital tax in that other State as

paid under the legislation of that State and in

conformity with the contract, estimated at the same fortune as

the one on which the Finnish tax is calculated.



b) dividends from companies established in another Contracting State

than Finland to companies resident in Finland are exempt from

taxation in Finland, if the recipient directly mastered at least 10

percent of the voting power in the company paying the dividends.



c) If resident in Finland from the other Contracting

State receives income of individual service referred to in article 15

paragraph 1 or article 21, paragraph 7 (a)) and that according to these

points may be taxed in that other Contracting State, shall

such income shall be exempt from Finnish tax.



d) If resident in Finland receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, or acquires

income pursuant to paragraph (c)) shall be exempt from Finnish tax,

Finland may include income or wealth in

the taxable amount but to put down the Finnish tax

on the income nor the wealth through the deduction of the part of the

the income tax and wealth tax charged on

the income received from the other State and

assets held there.



4. Iceland



a) where a resident of Iceland receives income or

holding assets in accordance with the provisions of this agreement

be taxable only or may be taxed in the other Contracting

State, Iceland shall, unless the provisions of subparagraph (b))

causing other things, reduce the income or

the wealth tax by deduction of that part of the income or

wealth tax charged on income received

from or the Fortune held in that other State.



b) where a resident of Iceland receives income which, in accordance with

the provisions of article 10, paragraph 7 of article 13, article 15

paragraph 3, article 16 or article 21, paragraphs 1-6 and 7 (c))

as well as 8 and 9 may be taxed in the other Contracting State, shall

Iceland Icelandic from this person's income tax set off a

amount equal to the income tax paid in that other

State settlement amount shall not, however, exceed the

part of the Icelandic tax, calculated without such a settlement,

attributable to the income which may be taxed in that other

State.



5. Norway



Unless the provisions in Norwegian legislation on the deduction from

Norwegian tax of tax paid in a territory outside Norway

causing other things (although the general principle set out

This change), the following applies:



a) where a resident of Norway receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Norway, unless

the provisions of paragraph b) or c) causing the other,



1) from the tax relating to the person's income offset a

amount equal to the income tax paid in that other

State,



2) from the tax relating to the person's fortune set off

an amount equal to the capital tax paid in

These property assets in that other State.



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

the tax on income or wealth, calculated without such

settlement, charged on the income and the

property assets which may be taxed in that other State.



b) where a resident of Norway receives income which, in accordance with

the provisions of this Agreement shall be taxable only in the other

Contracting State, may include income in Norway

the taxable amount but to put down the Norwegian tax

on income through deduction of that part of the income tax

charged on the income derived from that other State.



(c)) where a resident of Norway receives income referred to in

Article 15 paragraph 1 or article 21, paragraph 7 (a)), Norway

the inclusion in income in the tax base, but shall bring down

the Norwegian tax on income by subtracting the portion of

income tax attributable to the income derived from this

other State.



6. Sweden



a) where a resident of Sweden receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Sweden, unless

the provisions of paragraph b) or c) causing the other,



1)-subject to the provisions of Swedish legislation

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

that the general principle as stated this change)-from tax

on income set off an amount equal to the income tax

paid in that other State;



2) from this person's Swedish wealth tax set off a

amount equal to the capital tax paid in this

other State. 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

that other State.



b) where a resident of Sweden from other Contracting

State receives income of individual service referred to in article 15

paragraph 1 or article 21, paragraph 7 (a)) and that according to these

points may be taxed in that other Contracting State, shall,

Notwithstanding the provisions of paragraph (a)), such income

shall be exempt from Swedish tax.



(c)) where a resident of Sweden receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, or acquires

income pursuant to paragraph (b)) shall be exempt from Swedish tax,

Sweden may, when determining the tax rate for the Swedish

progressive tax on other income or capital, take into account the

income or wealth which shall be taxable only in the other

Contracting State or such income shall be exempt from

Swedish tax.



7. Common provisions



1. The phrase "paid in that other State" in this article

are also considered to include the tax on income paid in

Denmark, Faroe Islands, Finland, at the in Iceland, Norway and

Sweden and to be transferred to that other State for the purpose of

where the person credited him as a tax on the same income.



2. If a person resident in one Contracting State

(the State of residence) from another Contracting State

(the State) receives income of individual service

Article l5 point 1 or article 21, paragraph 7 (a)),

taxation in the State of employment, the State of residence, without barriers

the provisions of paragraphs 1 (c)), 2 c), 3 (c)), 4 (a)), 5 (c))

or 6 b) of this article, eliminate double taxation by

deduction of the tax paid in the other State with

the application of the provisions of paragraphs 1 (a)), 2 a), 3 (a)), 4

b), 5 (a)) or 6 (a)) if the person in question has acquired income

from company or permanent establishment in the State, and he

is, or immediately before taking up employment in the State

been employed in



(a) the State of which the company outside) is a company with

Community of interest with the company in the State, or



(b)) the State to which the company outside the fixed

establishment belongs.



3. the provisions of paragraphs 1 (c)), 2 c), 3 (c)), 4 (a)), 5 (c))

or 6 (b)) shall, notwithstanding the provisions of

the preceding paragraph shall apply if the person in question can show

to



a) he resided in and work in the State under a

continuous period during the tax year in question

exceeding three months, or



b) work carried out in the State for each

costs rightly were charged to the company in this State

or that located permanent establishment.



Article 26



General taxation rules



1. income as a resident of a Contracting State

acquires or wealth as such person holds may not

be taxed in the other Contracting State, unless the taxing

expressly permitted by this agreement.



2. In cases where tax to an income or asset

under the agreement added to the other Contracting State than the one where the

the person who acquires or holds income access has

the resident, and the other State by virtue of their legislation does not

take the income or asset, in its entirety, at

taxation or only takes into account income or asset

for progression or other tax calculation,

taxable income or asset, unless otherwise

provided below, to the extent that it not be taken at the

taxation in that other State, be in the Contracting

State in which the person concerned is resident.



3. In cases where the right to tax under article 14, paragraph 1, and

Article 15, paragraph 2, and paragraphs 4 (a)) and 4 (b)) to an income

acquired by a resident of a Contracting State

under the contract, added only this State, income

be taxed in the other Contracting State, such income may not

be taxed in that State by reason of the laws of the

This state.



Article 27



Prohibition of discrimination



1. nationals of a Contracting State shall not in other

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 conditions, in particular as

relating to residence, are or may be subject to. Notwithstanding the

the provisions of article 1 shall apply this provision also

person who is not habitually resident in one or more of the

Contracting States.



2. the taxation on a permanent establishment or a permanent

device, as a company or person resident in a

Contracting State has in the other Contracting State, shall, in

that other State shall not be less favourable than the taxation

of company or person by a resident of the other State, that

operating out of the same kind.



This provision is not considered to entail the obligation for an

Contracting State to grant to a resident of the other

Contracting State such personal deduction for tax purposes,

such exemptions or reductions because of

marital or dependent on family permitted person

established in the first State. The provision does not

either the right of a Contracting State to obtain deductions for

taxation or tax exemption for dividends or other

payment to company resident in the other Contracting State.



The first subparagraph does not prevent a

Contracting State to tax income, permanent establishment

acquire, under the rules of that State's own law, if

the permanent establishment belongs to a limited liability company, or

similar companies in other Contracting State Taxation

shall be equal to the tax that is applied for

limited liability company or similar companies resident in the

first-mentioned Contracting State on its income, estimated

without deduction of the distributed profits.



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 tax 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 one or more of the other

Contracting States shall not be in the first State

be subject to taxation or related requirements

that is other or more burdensome than the taxation and

related 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 28



The procedure for the mutual agreement



1. where a person considers that one or more of the Contracting

States have taken measures to him causes or will

that lead to taxation contrary to the provisions of this

Agreement, he may, without prejudice to his right to use

the remedies available in those States ' internal

legal orders, submit the matter to the competent authority in

the Contracting State of which he is a resident or, if the question is

on the application of article 27, paragraph 1, of the Contracting

State of which he is a national. The matter should be presented within five years

from the time the person in question had knowledge of the

action giving 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,

the authority shall seek decide by mutual

agreement with the competent authority of the other Contracting

State, concerned by the issue, in order to avoid taxation which

contrary to the agreement. If the State whose competent authority

the person in question has presented the thing not itself affected by

the question, shall submit the matter to the competent authority

the competent authority of any of the States concerned by the matter.

Agreement is carried out without prejudice

deadlines in the appropriate Contracting States ' internal

legislation.



3. where difficulties or doubts arise between

Contracting States concerning the interpretation or

the application of the agreement, the competent authorities of

These States discuss to try to solve the issue through mutual

agreement. The competent authorities of the Contracting

States can also consult to eliminate double taxation in

such cases not covered by the agreement or by

mutual agreement resolve issues, without being

regulated in the agreement, because of the difference in the appropriate State

principles for the calculation of taxes or for other reasons,

arise in relation to the taxes referred to in article 2.



4. Before making a decision in the case referred to in paragraph 3, the

the result of the consultations referred to therein as soon as notified

the competent authorities of other Contracting States. Finds

competent authority of a Contracting State that deliberations

should take place between the competent authorities of all

Contracting States, shall, at the request of the competent

authority of the first-mentioned Contracting State such

consultations take place without delay.



Article 29



Members of the diplomatic mission or consular post



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

the diplomatic mission or consular post.



Article 30



Territorial expansion



1. this agreement, either in its entirety or with any necessary

changes should be extended to cover the areas excluded

from tilllämpningsområde in accordance with the provisions of the agreement

Article 3, paragraph 1 (a)), provided that where the accrual

treasures of the same or substantially similar kind as those

referred to in the agreement. Such extension applies from the day and with

the modifications and conditions, including rules on

termination, which can especially be agreed between the

Contracting States through diplomatic exchange of notes.



2. If the contract pursuant to article 32 shall cease to apply, unless

not otherwise agreed between the Contracting States,

the agreement shall cease to be valid also for each area to

which the agreement has been extended under this article.



Article 31



Date of entry into force



1. This agreement shall enter into force on the thirtieth day after the then-

all the Contracting States have notified the Finnish

the Ministry of Foreign Affairs, that the contract has been approved. The Finnish

the Ministry of Foreign Affairs to inform the other Contracting

States on receipt of these messages and the timing

for the entry into force of the agreement.



2. Since the entry into force of this agreement, apply its provisions



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

that this agreement enters into force or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after this agreement enters into force, or

later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year following the

This agreement enters into force or later.



3. Notwithstanding the provision of article 15, paragraph 3 shall be taxable

income of the work covered by this provision only in the

the Contracting State whose nationality the ship has. This

provision for taxes relating to the calendar year,

immediately after the year in which the agreement enters into force, and the

the next two closest to the following calendar years.



4. The agreement of 12 september 1989 between the Nordic countries

for the avoidance of double taxation with respect to taxes on

income and wealth ceases to be applicable in the case

If the income or wealth on which the present agreement becomes

applicable in accordance with paragraph 2. The first agreement ceases to

apply for the last time, then this agreement pursuant to the preceding

provisions of the said paragraph becomes applicable.



5. the provisions of paragraphs 2 and 3 of section VII, respectively, in

paragraphs 2 and 3 of section VIII of the Protocol to the agreement on

12 september 1989 shall, however, continue to apply to the person who

on 1 January 1997 satisfying and time then continues

satisfies the conditions laid down in those provisions. Time to time and

with the June 30, 1997 shall be taken into account in the calculation of

the six-month period in point 4 of paragraph VII and paragraph 4

in section VIII of the Protocol to that agreement. From shorter

interruptions, such as vacation, maternity leave, etc. shall take

will be disregarded. The detailed rules for the application thereof

be agreed by mutual agreement between the

competent authorities in Denmark and Sweden.



Article 32



Termination



A Contracting State may, by 30 June of a

calendar year beginning after the expiration of a period of five years

After the date of entry into force of the agreement to terminate the agreement

by written notice to the Finnish

the Ministry of Foreign Affairs, informing the other Contracting

States of the receipt of such notice and if its

content. The period of notice has been complied with, the contract ceases to


apply in the relationship between the State which implemented the

termination and other Contracting States



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

It then the Finnish Ministry of Foreign Affairs received the message about

termination or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after that when the Finnish Ministry for Foreign Affairs took

receive notice of termination or later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year closest to

After the Finnish Ministry of Foreign Affairs received the message

If termination or later.



The original copy of this agreement deposited with the Finnish

the Ministry of Foreign Affairs, which provides the other Contracting

States certified copies thereof.



In witness whereof, the duly accredited

the delegates have signed this agreement.



Done at Helsinki on 23 september 1996, in a single copy

in Danish, Faroese, Finnish, Icelandic, Norwegian and Swedish

languages, with the Swedish language was issued two texts, one

for Finland and for Sweden, each of these texts have the same

validity.



Protocol



At the signing of it today between the Nordic countries

Agreement for the avoidance of double taxation with respect to

taxes on income and on capital, the undersigned have come

agree on the following provisions which form an integral part

of the agreement:



I. to articles 7 and 15



1. Notwithstanding the provisions of article 7 are taxed income,

What companies in Norway or Sweden acquires through activities

carried out in Sweden and Norway, only in the State in which the

the company is domiciled, on activities relating to the set and

maintenance of spärrstängsel for reindeer on routes along the

the Norwegian-Swedish border, which routes specified in

agreement referred to in paragraph 4.



2. Notwithstanding the provisions of article 15 are taxed

income, any person resident in Norway or Sweden

acquires through personal work done in Sweden

and Norway, only in the State in which that person has

the resident, if the work relating to the collection and maintenance of

spärrstängsel for reindeer on routes along the Norwegian-Swedish

riksgränsen, which routes specified in the agreement referred to in

point 4.



3. the provisions of paragraphs 1 and 2 concerning the company in,

each person resident in Norway or Sweden shall be

the corresponding application relating to the undertakings in, respectively,

person resident in Finland or Norway.



4. the competent authorities of the Contracting States

shall by mutual agreement determine the routes

along he border to which the provisions of

paragraphs 1-3 shall apply.



II. To articles 7, 10-15, 19 and 23



1. Notwithstanding the provisions of article 7, article 10 paragraph

2, article 11, paragraph 2 and article 12 paragraph 2 are taxable income,

as a company in Denmark or Sweden, which participates in the construction

and operation of the fast links over Öresund acquires, in the

so far as the income is obtained for the construction and operation of the bridge

and the associated tunnel connection, only

in the State where the company is domiciled. The same applies

income that such a company acquires to the extent that the income

obtained for the construction and maintenance of the artificial island.



2. Notwithstanding the provisions of article 13 paragraph 3 be taxed

the win, which businesses in or resident in Denmark or

Sweden which or which participates in the construction and operation of the

fixed links over Öresund acquires due

the transfer of the property, which is used in the construction

and the operation of the bridge and the related

tunnel connection, only in the State where the company respectively

the person is a resident. Corresponding profit as such

company or such person acquires the alienation of

such property which is used in the construction and maintenance of

the artificial island.



3. Notwithstanding the provisions of article 14, paragraph 1, article

15 paragraph 1 and article 19 taxed income, as a person with

resident in Denmark or Sweden acquires from companies like

involved in the construction and operation of the fixed links across

Sound, on the work relating to the construction and operation of the bridge

and the associated tunnel connection, only

in the State where the person is a resident. The same applies to income

as such person acquires about the work relating to the construction and

maintenance of the artificial island.



4. Notwithstanding the provisions of article 23, paragraph 6 shall be taxable

the capital, businesses in or resident

in Denmark or Sweden holds and used in construction

and the operation of the bridge and the related

tunnel link across the Øresund Strait, only in the State in which the

the company and the person's place of residence. The same applies

fortune as such company or person holds and

used in the construction and maintenance of the artificial

the island.



III. To articles 7, 8, 13, 15 and 23



1. the provisions of article 7, article 8, paragraph 1, article 13

paragraph 4, and article 23, paragraph 3 shall be applied in Denmark, Norway and

Sweden on income which the consortia Scandinavian Airlines

System (SAS), Scanair or SAS Commuter acquires through

international and domestic aviation and other

thereby directly contiguous operations, on capital gain

the Consortium acquires on the sale of movable property

used in such aviation and such other activities and on

Fortune consortium holds and used in such a

Aviation and such other activities, in relation to the

share in the Consortium held by a shareholder who is resident in

Denmark, Norway and Sweden.



2. the provisions of paragraph 1 shall be applied upon agreement

between the competent authorities of Denmark, Norway and Sweden

also in the case of another consortium or other similar

Association for the operation of air services or other

direct continuous activity, in which the Association

only co-owners of SAS, directly or indirectly, holds shares and

What are essentially structured in accordance with the principles

apply to SAS.



IV. Ad article 13



The provisions of article 13, paragraphs 6 and 7 shall not affect the

a Contracting State that, according to its own legislation

taxing capital gains as a person who moves from this

State shall be deemed to have received in connection with the transfer.



V. to article 15



1. In article 15, paragraph 2 (d)) shall be deemed to workers resident in a

Contracting State rented when he by someone (lessor)

available to perform work in another's (client)

activities in the other Contracting State, provided that the

principal residence or permanent establishment in this

other State and that the lessor is not responsible for and does not

nor is the risk of working results.



2. for the determination of the question whether an employee shall be deemed to

leased, must be taken into account in particular

If



(a)) the overall management rests with the principal,



(b)) the work is performed at a workplace as appropriated by the

the principal and for which he has responsibility,



c) compensation to the lessor are calculated after the time elapsed

access or to the relationship between the remuneration and

the salary the worker may,



d) most of the work tools and materials should be addressed to the

disposal of the client, and



e) landlord cannot unilaterally determine the number of workers and

the qualifications they should have.



3. Notwithstanding the provisions of article 15, paragraphs 1 and 2

shall pay or other similar remuneration, as a person with

a resident of Denmark receives due to work being carried out on board

the Danish train, and as a resident of Sweden

drawing on the basis of work carried out on board the Swedish rail system, in

traffic between Denmark and Sweden, shall be taxable only in the State

where the person is a resident.



Vi. To articles 15 and 19



1. Notwithstanding the provisions of article 15, paragraphs 1 and 2

and article 19, paragraph 1 shall be taxable income, the person with the

resident in the municipality in Finland or Norway, bordering

the land border between these States acquire due

personal work performed in such municipality, the other of

These States, only in the State where the person concerned has

habitual residence, provided that such person regularly

reside in their permanent residence in that State.



2. Notwithstanding the provisions of article 15, paragraphs 1 and 2

and article 19, paragraph 1 shall be taxable income, the person with the

resident in the municipality in Finland or Sweden which border

the land border between these States acquire due

personal work performed in such municipality, the other of

These States, only in the State where the person concerned has

habitual residence, provided that such person regularly

reside in their permanent residence in that State.



3. Notwithstanding the provisions of article 15, paragraphs 1 and 2

and article 19, paragraph 1 shall be taxable income, the person with the

resident in the municipality in Norway or Sweden bordering

the land border between these States acquire due

personal work performed in such municipality, the other of

These States, only in the State where the person concerned has

habitual residence, provided that such person regularly

reside in their permanent residence in that State.



4. The term ' habitually resident ' means that the


taxpayer is normally at least once a week staying

in their permanent residence in the Contracting State in which he has

resident. To a taxpayer shall be deemed to reside in

their permanent residence in the State of residence shall cover at least the

two days. In that case, as well as the remainder of the agreement which

the term "day" is found, that with "day" refers to the part of the

today.



VII. To article 18



1. Notwithstanding the provisions of article 18 shall in

the relationship between Denmark and the Faroe Islands the following shall apply:



Pensions, annuities, social security benefits,

alimony and other similar payments arising

from a part of the Kingdom and paid to a resident of the

the other part of the Empire, be taxable only in that other part of the

Empire.



2. The expression "social compensation" includes,

in respect of Denmark, "orlovsydelser".



VII. a) to article 18



1. Notwithstanding the provisions of article 18, paragraph 1,

Finland to apply the following provisions:



Pension and annuity payable from other Contracting State

than Finland and payment from the other Contracting State than

Finland under social legislation in this State to a person

resident in Finland shall be taxable only in the first-mentioned

State. This applies if the person domiciled in Finland on 4

April 2008 and at this time received such payment.

The provisions apply only so long as the person without

interrupts are still domiciled in Finland.



2. Notwithstanding the provisions of article 18, paragraph 1,

Sweden to apply the following provisions:



Pension and annuity payable from other Contracting State

than Sweden and payment from the other Contracting State than

Sweden under social legislation in this State to any person

a resident of Sweden shall be taxable only in the first-mentioned

State. This applies if the person was resident in Sweden on 4

April 2008 and at this time received such payment.

The provisions apply only so long as the person without

interrupts are still domiciled in Sweden.



VIII. To article 19



1. Notwithstanding the provisions of article 19 shall have the following

apply in the relationship between Denmark and the Faroe Islands:



a) salaries and other similar compensation (except for retirement)

paid by a part of the Kingdom, one of its political

subdivisions or local authorities, to a natural person

because of the work done for this part of the Empire,

subdivision or authority shall be taxable only in that part of the

Empire where the work is performed.



b) Notwithstanding the provision of paragraph a) taxed wages and

other similar compensation, as a resident of part of

the Kingdom receives for personal work in the employment relationship

conducted in a different part of the Empire, only in the first part

of the Kingdom, if:



1) recipient resides in this second part of the Empire during the

time period or periods totalling not more than

120 days in any twelve-month period, and



2) salary or compensation paid by the "usual

service rather than ".



c) the provisions of articles 15 and 16 as well as in the Protocol section

VII applicable to wages and other similar remuneration received

for work performed in the course of trade which is carried out by a

part of the Kingdom, one of its political subdivisions, or

local authorities.



2. Notwithstanding the provisions of paragraph 1, the following shall apply

the relationship between Denmark and the Faroe Islands:



a) compensation, laid down by the general exclusion

to cover expenses in connection with General or individual

service, and that does not include any remuneration for work and

that the Danish State, one of its political subdivisions

or local authorities pay to the person working on

Faroe Islands shall be taxable only in Denmark,



b) remuneration as established by the general exclusion for

to cover expenses in connection with General or individual service

and that does not include any remuneration for work and that

The Faroe Islands, one of its political subdivisions

or local authorities pay to the person who works in

Denmark is taxed only on the Faroe Islands.



The provisions of paragraphs a) and b) applied during the first

five years during which the person concerned is in receipt of the said

employee benefits.



IX. To article 20



1. Person residing in other Contracting State than on the Faroe Islands

and the person who is staying in the other Contracting State than in Iceland

exclusively for



a) studies at the educational establishment in that other State, if the studies are

the aid of public funds can be obtained in

that State, or



b) business, fisheries, industry, agriculture or

forestry practical training in the other State,



and that has, or immediately prior to their domicile on

Faroe Islands or in Iceland, is taxed on income from employment in

the first-mentioned Contracting State solely for the part of

income in excess of 20 000 Swedish kronor during

calendar year or the equivalent in Danish, Finnish, Icelandic or

Norwegian coin types. That amount covers during the stay in

Finland, Norway or Sweden personal deduction for the calendar year

in question.



2. the exemption from taxation referred to in paragraph 1 shall be allowed only for the time

reasonably or normally used for the studies or

traineeship, up to a maximum of six consecutive

calendar year.



3. Notwithstanding the provisions of paragraphs 1 and 2 shall

the following shall apply in the relationship between Denmark and the Faroe Islands:



Student, trainee or similar who have or who

immediately prior to their part of the Empire had established in the

the second part of the Kingdom and who are temporarily staying in the

the former part of the Reich exclusively in study or

educational purposes is not taxed in this part of the Empire for the amount

obtained from the other part of the Empire or from abroad

for living expenses, education or training.



Nor is it taxed for the amount payable as compensation

for work, if such work is necessary for their subsistence.



Student, trainee or similar which, immediately prior to

the stay in Denmark was habitually resident in the Faroe Islands, is not taxed on

Faroe Islands for compensation for work done in Denmark.



As a student is not considered to be people who, having completed a

education, begin special training or education

in a new area.



A stay is considered temporary if it does not exceed the

regulated studies with an extension of two years.



A stay is not considered to be "exclusively in the study or

educational purposes "if it lasted more than six months before the

the studies began.



In this six-month period shall not be included in such period, however,

a maximum of one year, as used in the context of a preparatory course

According to the educational institution is a prerequisite to

able to begin studies in question.



In cases where two spouses applying to be adopted at

educational institution and only one of them adopted, are

six of the other spouse, but not more than

for a total period of two years.



4. Notwithstanding the provisions of paragraph 1 shall be taxable

student, trainee or similar that has, or immediately

before the stay in Denmark was habitually resident in Iceland and that

temporarily staying in Denmark exclusively in study or

educational purposes not for amounts paid as consideration for

work, provided that the work is necessary for his

living expenses.



5. A Person who is resident in the other Contracting State than

Denmark and that during a temporary stay in Denmark are employed in

Denmark for up to 100 days in a calendar year

taxed in Denmark only for that portion of the income that

exceed an amount according to the current provisions are considered to

be required for his subsistence, provided that

the work is performed within the framework of the Nordic programme for the exchange of

Internships and working holiday and that the work has been conveyed by

Nordjobb.



The amount deemed necessary for his/her

subsistence is determined on an annual basis and reduces the relative

to the duration of residence in Denmark and throughout the calendar year.



6. the competent authorities of the Contracting States may

reach agreement on the application of the provisions of

paragraphs 1 to 5. The competent authorities may also meet

mutual agreement if such modification of where mentioned

amount that is reasonable in view of the change in

monetary value, amended legislation in one of the Contracting

States or other similar circumstances.



X. To article 25



1. The provision of article 25 paragraph 1 c) may be waived upon request

of Denmark.



Request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change becomes effective thirtieth day after the date of

all other Contracting States received such

notice with effect on taxes that are determined for

tax year that begins on 1 January of the calendar year in which

immediately after the amendment comes into force, or

later.



The provisions of article 25 paragraph 1 may, at the request of Denmark

amended and replaced by the following text:



"a) where a resident of Denmark receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Denmark, unless

the provisions of paragraph b) or c) causing the other,



1) from this person's Danish income tax set off an amount

equivalent to the income tax paid in that other State;



2) from this person's Danish capital set off a

amount equal to the capital tax paid in this

other State.




Settlement amount shall not, however, exceed

the part of the Danish income tax or property tax,

calculated without such a settlement, charged on the income or

Fortune may be taxed in that other State.



b) where a resident of Denmark receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, Denmark

include the income or assets in the taxable amount

but shall bring down the Danish tax on income or

the fortune by deduction of that part of the income tax

respective wealth tax levied on the income

derived from the other State and fortune

held there.



(c)) where a resident of Denmark receives income referred to

in article 15, paragraph 1 or article 21, paragraph 7 (a)), Denmark

the inclusion in income of taxable amount but to put down

the Danish tax on income by subtracting the portion of

income tax attributable to the income derived from this

other State. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change becomes effective thirtieth day after the date of

all other Contracting States received such

intelligence and its provisions apply in the case of tax

at Fortune, wealth on which tax is paid on account

by assessments on other calendar year after the date of the change

enters into force, or later.



2. the provisions of article 25, paragraph 2, may, at the request of

Faroe Islands changed and replaced by the following text:



"a) where a resident of the Faroe Islands receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, the Faroe Islands, unless

the provisions of paragraph b) or c) give rise to the other, from

This person's Faroese income tax or wealth tax

deduct an amount equal to the income tax or

property tax paid in that other State.



Settlement amount shall not, however, exceed

the part of the Faroese income tax or

the wealth tax, calculated without such a settlement, charged

on the income or wealth that may be taxed in that

other State.



b) where a resident of the Faroe Islands receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, Faroe Islands

include the income or assets in the taxable amount

but to reduce the tax on income, Faeroese, or

the fortune by deduction of that part of the income tax or

wealth tax levied on income derived from

the other State or of the fortune that may be taxed in the

that other State.



c) if the person on the Faroe Islands from other Contracting

State receives income of individual service referred to in article 15

paragraph 1 or article 21, paragraph 7 (a)) and that according to these

points may be taxed in that other Contracting State, may

Faroe Islands include income in the tax base, but shall

reduce the income tax by deduction at the Faroese with

that part of the income tax levied on the income derived

from the other State. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change takes effect when the thirtieth day after all the

other Contracting States receiving such notification and

its provisions apply in the case of taxes on wealth,

fortune on which tax is paid on account of tax other

calendar year following that in which the change becomes effective, or

later.



3. the provisions of article 25 paragraph 3 may, at the request of

Finland amended and replaced by the following text:



"a) where a resident of Finland receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Finland, unless

the provisions of paragraph b) or c) causing the other, with

subject to the provisions of Finnish law (also in the

version in the future can get through to change without the

general principle referred to here are affected),



1) from this person's Finnish income tax set off an amount

equivalent to the income tax paid in that other State

under the law of that other State and in conformity

with the agreement, calculated on the same income as that on which the

Finnish tax is calculated;



2) from this person's Finnish property tax set off a

amount equal to the capital tax in that other State as

paid under the legislation of the other State and in

conformity with the contract, estimated at the same fortune as

the one on which the Finnish tax is calculated.



b) dividends from companies established in another Contracting State

than Finland to companies resident in Finland are exempt from

taxation in Finland, if the recipient directly mastered at least 10

percent of the voting power in the company paying the dividends.



c) If resident in Finland receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, Finland

include the income or assets in the taxable amount

but shall bring down the Finnish tax on the income or

the fortune by deduction of that part of the income tax

respective wealth tax levied on the income

acquired from the other State and fortune

held there. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change takes effect when the thirtieth day after all the

other Contracting States receiving such notification and

its provisions apply



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

the time change takes effect or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after the amendment comes into force, or

later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year following the

When the amendment enters into force, or later.



4. the provisions of article 25, paragraph 4, may, at the request of Iceland

amended and replaced by the following text:



"a) where a resident of Iceland receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, the Iceland, unless

the provisions of paragraph (b)) gives rise to different,



1) from this person's Icelandic income tax set off an amount

equivalent to the income tax paid in that other State;



2) from this person's Icelandic net wealth tax set off a

amount equal to the capital tax paid in this

other State.



Settlement amount shall not, however, exceed

that part of the income tax or

the wealth tax, calculated without such a settlement, charged

on the income or wealth that may be taxed in that

other State.



b) where a resident of Iceland receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, Iceland

include the income or assets in the taxable amount

but shall bring down the Icelandic tax on income or

the fortune by deduction of that part of the income tax

respective wealth tax levied on the income

derived from the other State and fortune

held there. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change takes effect when the thirtieth day after all the

other Contracting States receiving such notification and

its provisions apply



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

the time change takes effect or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after the amendment comes into force, or

later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year following the

When the amendment enters into force, or later.



5. the provisions of article 25, paragraph (5) may, at the request of Norway

amended and replaced by the following text:



"Unless the provisions in Norwegian legislation on the deduction from

Norwegian tax of tax paid in a territory outside Norway

causing other things (although the general principle set out

This change), the following applies:



a) where a resident of Norway receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Norway



1) from the tax relating to the person's income offset a

amount equal to the income tax paid in that other

State,



2) from the tax relating to the person's fortune set off

an amount equal to the capital tax paid in

These property assets in that other State.



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


the tax on income or wealth, calculated without such

settlement, charged on the income and the

property assets which may be taxed in that other State.



b) where a resident of Norway receives income which, in accordance with

the provisions of this Agreement shall be taxable only in the other

Contracting State, may include income in Norway

the taxable amount but to put down the Norwegian tax

on income through deduction of that part of the income tax

charged on the income derived from the other State. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change takes effect when the thirtieth day after all the

other Contracting States receiving such notification and

its provisions apply



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

the time change takes effect or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after the amendment comes into force, or

later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year following the

When the amendment enters into force, or later.



6. the provisions of article 25, paragraph 6 may, at the request of

Sweden changed and replaced by the following text:



"a) where a resident of Sweden receives income or

holding assets in accordance with the provisions of this agreement,

be taxed in the other Contracting State, Sweden, unless

the provisions of paragraph (b)) gives rise to different,



1)-subject to the provisions of Swedish legislation

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

that the general principle as stated this change)-from tax

on income set off an amount equal to the income tax

paid in that other State;



2) from this person's Swedish wealth tax set off a

amount equal to the capital tax paid in this

other State. 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

that other State.



b) where a resident of Sweden receives income or

holding assets in accordance with the provisions of this agreement

shall be taxable only in the other Contracting State, Sweden, at

the determination of the tax rate for Swedish progressive tax on

other income or capital, take into account the income or

Fortune shall be taxable only in the other Contracting

State. "



The request for such a change is made by diplomatic means through

notice to each of the other Contracting States.

The change takes effect when the thirtieth day after all the

other Contracting States receiving such notification and

its provisions apply



(a)) in respect of taxes on income at source of content, as

acquired on 1 January of the calendar year immediately following

the time change takes effect or later,



(b)) in respect of other taxes on income, for taxes to be determined

for tax years beginning on 1 January of the calendar year in which

immediately after the amendment comes into force, or

later,



(c)) in respect of tax on wealth, on the fortune of the

tax is paid on the basis of assessments other calendar year following the

When the amendment enters into force, or later.



XI. To article 26



The provisions of article 26, paragraph 3 shall be equivalent

application in the cases referred to in point II of the Protocol, paragraphs 3

and 4.



XII. in article 31



1. for the purposes of taxation in the construction, maintenance and operation

of border bridges, etc. over the border between Finland and Norway,

for what is thereupon agreed.



2. in the case of exemption from taxation in Finland and Sweden for

floating Coalition, formed to manage timber floating in the

The Tornio and Muonio gränsälvars retrieved 11 July 2010, for what thereupon

specifically agreed.



The original of the certificate to this Protocol deposited with the

Finnish Ministry of Foreign Affairs, which provides the other

Contracting States certified copies thereof.



In witness whereof, the duly accredited

the delegates signed this Protocol.



Done at Helsinki on 23 september 1996, in a single copy

in Danish, Faroese, Finnish, Icelandic, Norwegian and Swedish

languages, with the Swedish language was issued two texts, one

for Finland and for Sweden, each of these texts have the same

validity. Law (2008:653).



Annex 2



Agreement



between the Government of the Kingdom of Sweden and the Kingdom of Denmark

Government on taxation of employees on board ferries and trains in

regular service between Denmark and Sweden



In the relationship between Sweden and Denmark,

under the agreement, 23 september 1996 between the Nordic

countries on the avoidance of double taxation with respect to taxes

on income and on capital.



Article 1



1. Notwithstanding the provisions of article 15 are taxed

income, as a person resident in Denmark or Sweden

acquire through work on trains in regular service

exclusively between Denmark and Sweden only in the

Contracting State in which the employer is established. Such

income may also be taxed in the Contracting State

where the person is a resident. A prerequisite for the application of

This point, however, is that the work is done on the train in

cross-border traffic and that the person carrying out the work in both

countries in a single day. With cross-border traffic

referred to traffic originated in Denmark and terminated in Sweden

each begins and ends in Sweden in Denmark.



2. Notwithstanding the provisions of article 15 and article 31

paragraph 3 shall be taxable income, as a person resident in Denmark

or Sweden acquires through work performed on board the Danish

or Swedish ships in international ferry traffic between Denmark

and Sweden only in the Contracting State in which the employer

is domiciled. However, such income may also be taxed in the

Contracting State in which the person is domiciled. With

international ferry services "means the carriage of passengers and

freight in regular service exclusively between ports in Denmark and

port in Sweden.



Article 2



The provision in paragraph 3 of point V of the Protocol shall no longer

applied.



Article 3



This agreement shall enter into force on the 21st day after the day

When the States concerned shall have notified each other that the

the constitutional measures required in each State

taken, and its provisions shall be applied in the case of

taxes on income as determined for taxation years that begin

on 1 January of the calendar year immediately following the year in which the

the agreement enters into force or later. Law (1999:999).



Annex 3



Agreement



between the Kingdom of Sweden and the Kingdom of Norway concerning special

provisions for the avoidance of double taxation in connection with the construction,

and maintenance of the frontier bridge which is part of the new

The svinesund connection



The Government of the Kingdom of Sweden and the Kingdom of Norway

Government,



who considers it necessary to for the construction, maintenance and operation

of the border bridge that is part of the new Svinesund connection

provide for certain exemptions from the provisions of the agreement between the

the Nordic countries to avoid double taxation

with respect to taxes on income and on capital, signed

in Helsinki on 23 september 1996, and



Desiring to conclude an agreement on specific provisions for

avoidance of double taxation in connection with the construction, maintenance and

operation of the border bridge that is part of the new Svinesund connection,



have agreed as follows:



Article 1



1. the provisions of this Agreement shall apply without prejudice to

the provisions of the agreement between the Nordic countries in order to

avoidance of double taxation with respect to taxes on income and on

Fortune, signed in Helsinki on 23 september 1996.



2. the provisions of this agreement apply to a person with

resident in Norway or Sweden performing work or conducting other

operations in Sweden and Norway in connection with the construction,

maintenance and operation of the new bridge across the Svinesund.



3. any statements that are not defined in the agreement, shall have the

significance of expression of the agreement between the Nordic

countries referred to in paragraph 1.



Article 2



This agreement shall apply to the Norwegian and Swedish taxes

covered by the agreement between the Nordic countries listed in

Article 1.



Article 3



With "bro" is understood in this agreement to the actual

bridge structure, lighting devices and other devices

on or in connection with this, the necessary devices and

area of land for construction, and tillfartsbankar, all in

compliance with the approved plan or drawing.



Article 4



1. for the purposes Of reconstructing the building also, improvement,

change, moving, demolition and other similar work

in connection with the construction, as well as investigative and

preparatory work undertaken in direct connection to the site

for the construction of the bridge.



2. for the purposes Of repair, maintenance and replacement of parts

and other materials, inspections, monitoring and inspection,

cleaning and lighting as well as protection and service operations,

plowing, sanding and chassis operations.



3. this Agreement shall also apply to the dozing-and

areas and other related or comparable

work carried out in connection with the construction, maintenance or operation

of the bridge.



Article 5




Income or profits that are acquired or fortune held

of person resident in Norway or Sweden, in below

cases shall be taxable only in the State where the person has

place of residence:



a) income because of employment or due to

independent professional activities or because of other activities in

associated with the construction, maintenance or operation of the bridge,



b) profits obtained from the sale of assets that are available on the

or adjacent to the bridge, and used in the construction,

maintenance and operation of the bridge,



c) fortune which consists of assets used in

the construction, maintenance or operation of the bridge.



Article 6



This agreement shall enter into force on the fourteenth day after the date of

the Contracting States shall have notified each other

If the contract is approved. The agreement shall apply to taxes on income

and fortune laid down for each of the fiscal years

starting on 1 January of the calendar year immediately following

the year in which this agreement enters into force, or later.



Article 7



A Contracting State may terminate the agreement by

notice to the other Contracting State not later than

June 30, any calendar year. In the event of such termination ends

the agreement will apply in respect of taxes on income and capital

laid down for the tax year that begins on 1 January

the calendar year immediately following the year in which the termination

took place or later. Law (2002:982).



Annex 4



Agreement



between the Kingdom of Sweden and the Kingdom of Denmark on certain

tax issues



In the relationship between Sweden and Denmark,

in relation to the agreement on 23 september 1996 between the

Nordic countries to avoid double taxation with respect to

taxes on income and on capital.



Article 1



1. where a resident of a Contracting State receives a salary

or other similar remuneration on account of employment, as

typically performed in the other Contracting State, of a

employer resident in the other State, or in a fixed

establishment or a permanent device, that person's

the employer has in that other State, the work of the

application of article 15, paragraphs 1 and 2 shall be deemed to be performed in

the other State, even if the work actually carried out in the

first State or in a third State, if



a) work in the first State are carried out by the person in his

residence, or



(b)) work in the first State or in a third State

is business travel, or other work of an occasional nature,



but only if the work in the other State is at least

half of the working time for each three-month period.



2. the provisions of paragraph 1 apply to



(a)) in cases where the employer is not domiciled in the other

Contracting State only if the salary or other similar

compensation to which the person concerned receives then charged to a permanent establishment

or a permanent device, which the employer has in the

other State,



(b)) in cases where the employer is a resident of the other

Contracting State only if the salary or other similar

compensation to which the person concerned receives are not charged a fixed

establishment or a permanent device, which the employer

in the first-mentioned Contracting State.



Article 2



1. If a natural person receives income in operating,

independent profession or employment, which, according to

Article 7, 14, 15 or 19 may be taxed or taxed only

in a Contracting State and is connected to a

pension scheme in the other Contracting State, shall



a) instalment as this person does to the pension scheme be

deductible in the first State, and



b) payment that this person's employer makes to

the retirement scheme is not considered as taxable income in the

first State of the person and be deductible in this

State of the employer.



2. The payment shall only be deductible or not

are considered as taxable income in the former

Contracting State within the thresholds that apply to the

contributions to a pension scheme under the legislation of

both of the Contracting States.



3. This article applies only to:



(a)) in cases where a person, who may be taxed or taxed only in

the first-mentioned Contracting State for operating income,

independent profession or employment in that State, has

resident in the other Contracting State, such income constitutes

at least 75% of the person's total income in operating,

independent profession or employment after deduction of

the entire cost for acquiring earnings (net income),

and



(b)) in cases where a person, who may be taxed or taxed only in

the first-mentioned Contracting State for operating income,

independent profession or employment in that State, has

a resident of this State, if the person was connected to and

contributions made to the pension scheme immediately before

the person was domiciled in this State.



4. For the purposes of paragraph 1, the expression "pension scheme"

mean an arrangement, as



(a) in the case of Denmark) for the scope of

pension taxation Act section I,



b) for Sweden's part covered by 28 or 58.

the income tax Act (1999:1229).



Article 3



Natural persons ' travel across the Oresund bridge shall

be taken into consideration for the determination of taxable income, if

they relate to normal travel between permanentbostaden and

the workplace. However, the right to deduct only if

These general terms and conditions for what is provided for such trips

for example, the requirements are met at the time relating to profit. Expenditure

shall be calculated on the basis of the documented expenses

for the cheapest period subscriptions for travel by passenger car

and travel by public transport.



Article 4



Article 31 paragraph 5 does not include persons resident in

Denmark.



Article 5



1. The Contracting State which recognizes the right to tax

According to article 1, shall tax the income recipient in accordance with the

the legislation of that State as regards the taxation of

service revenue, even if the work actually carried out in the other

Contracting State or in a third State.



2. A Pension or annuity that is paid from a Contracting

State to a resident of this State, shall be taxable in the

accordance with the General rules of that State, even if that State

did not put down its taxation in connection with the payments

to this order, when the other Contracting State in accordance with

Article 2 has previously considered that the contributions paid



(a)) of the natural person is deductible, or



(b)) of the natural person's employer is not liable to tax

income for the natural person and the deductible

the calculation of the employer's taxable income.



3. the rules on deduction of payment to

pension scheme within the meaning of article 2 and of expense for travel over

The Öresund bridge under article 3 applies only if the physical

the person's income is taxed on a net basis, with the possibility of

less costs.



Article 6



In cases where a natural person resident in one Contracting State

receives income from employment in the other Contracting

State (gross income) and that income for a tax year

is not less than the equivalent of 150, 000

earnings before deduction of expenditure on the acquisition, shall

the other State to pay a compensatory amount to the

first State. This smoothing shall be effected by 1

October of the year following the tax year in question.

The compensatory amount shall, for the Danish side to be the

average primary municipal tax levied on income

taxed in Denmark by virtue of article 15.

The compensatory amount shall be the part of Sweden

average municipal tax levied on primary municipalities

Bill relating to income taxed in Sweden with the support

of article 15. This article is not the income that

person resident in one Contracting State acquires by

work performed on board the Swedish or Danish ship in

international traffic. The competent authorities of the

Contracting States may conclude a mutual agreement

If the detailed specification of the order for relief. With

"competent authority" means the authority to whom according to

double taxation agreement between the Nordic countries

assigned to be the competent authority. The Contracting

After two years, States intend to evaluate this scheme

in particular as regards the level of the Equalization and the fact that

leveling refers only to the part of the municipal tax levied

for primary municipalities ' behalf and not the part that is taken out of

County Council on behalf of the municipalities. Then an evaluation

every five years or when significant changes of

tax systems.



Article 7



1. this Agreement shall enter into force on the 21st day after the

day when the two Contracting States shall have notified

each other that the constitutional measures necessary in

each State has taken, and its provisions shall

apply as regards



(a)), article 2, article 3, article 5, paragraphs 2 and 3, as well as

Article 6 in respect of taxes on income levied on

fiscal years beginning on or after January 1, 2004, and



b) article 1, article 4 and article 5 paragraph 1 in the case of

taxes on income for fiscal years beginning on

1 January of the calendar year immediately following the year in which the

the agreement enters into force or later.



2. If it turns out to be fiscal barriers to the

continued integration of the Öresund region is Sweden and

Denmark agreed to begin discussions to consider


the introduction of new regulations or amendment of the provisions of

This agreement, or to initiate changes to the agreement

on 23 september 1996 between the Nordic countries in order to

avoidance of double taxation with respect to taxes on income and on

Fortune.



Article 8



A Contracting State may, not later than 30 June in any

calendar year to terminate the agreement by written notice

to the other Contracting State. Termination of this agreement, then that

apply to taxes on income imposed on behalf of

tax year that begins on 1 January of the calendar year in which

immediately after the year in which the termination occurs or later.



In witness whereof, the duly accredited

the delegates have signed this agreement.



Done at Copenhagen on 29 October 2003 in duplicate in

Swedish and Danish languages, both of which are equally authentic.

Act (2004:639).