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

income taxes that Sweden and Cyprus signed on 25 October 1988

shall apply for Sweden. Contents of the agreement are set out in annex to

This law.



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

involves restriction of the tax liability in Sweden that would otherwise

exist.



paragraph 3, If a person believes that it adopted any measure for him

causes or will result in taxation contrary to

the provisions of the agreement, he can seek redress under article 23

paragraph 1 of the agreement.



4 repealed by law (2011:1335).



Annex



Agreement between the Government of the Kingdom of Sweden and the Republic of Cyprus

Government for the avoidance of double taxation with respect to taxes on income



The Government of the Kingdom of Sweden and the Government of the Republic of Cyprus,

wish to conclude an agreement for the avoidance of double taxation with respect to

taxes on income, have agreed as follows:



Article 1

Persons to whom the agreement applies



This agreement shall apply to persons domiciled in a Contracting

State or in both Contracting States.



Article 2

Taxes covered by the agreement



1. this Agreement shall apply to taxes on income imposed for a

Contracting State, its political underavdelningars or local

authorities, irrespective of the manner in which taxes are levied.



2. taxes on income are understood all taxes paid on income in

as a whole or on elements of income, including taxes on the profits therein

from the alienation of movable or immovable property, as well as taxes on

capital appreciation.



3. The currently outgoing taxes, on which the agreement shall apply are



a) in Cyprus:



1) income tax



2) realisationsvinstskatten and



3) the special fee



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



b) in Sweden:



1) state income tax, withholding tax rate tax and seamen's

in that involved,



2) replacement levy and the tax statutes,



3) allocation fee for certain public performances,



4) the municipal income tax, as well as



5) profit-sharing tax



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



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

kind, which accrue after the signing of the agreement in addition to, or in the

rather than for the currently outgoing taxes. The competent

the authorities of the Contracting States shall each year notify

each other the essential changes that taken in tax legislation in

the respective State.



Article 3

General definitions



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

agreement the following expressions the following meaning:



a) "Cyprus" refers to the Republic of Cyprus, and include, if the expression

used in the geographical sense, the territory of Cyprus, Cyprus

territorial waters and the other maritime areas over which the Republic of Cyprus, in

accordance with the General rules of international law, exercises sovereign

rights or jurisdiction;



b) "Sweden '' refers to the Kingdom of Sweden and the includes, if the expression

used in geographical sense, the territory of Sweden, Sveriges

territorial sea and other maritime areas over which Sweden, in

accordance with the General rules of international law, exercises sovereign

rights or jurisdiction;



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

referring to the Republic of Cyprus or the Kingdom of Sweden as

context requires,



d) "person" includes a natural person, company or other association,



e) "company" refers to the legal person or other person for tax purposes

be treated as a legal person,



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

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

of a Contracting State, each company operated by any person with

resident in the other Contracting State,



g) "international traffic" refers to transport by ship or aircraft

used by the enterprises of a Contracting State, except when the ship or

the aircraft are used exclusively between places in the other

Contracting State,



h) "citizen '' refers to



1) natural persons who are nationals of a Contracting State, and



2) any legal person, partnership or association formed

According to the laws in force in a Contracting State, in) ' competent

authority "refers to



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



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

authority to which has been assigned to be a competent authority for the purposes

of the agreement.



2. Where a Contracting State applies, unless the contract is considered

context gives rise to different, each expression that is not defined in the

the agreement have the meaning the term has under the State's

legislation in respect of such taxes to which the agreement applies.



Article 4

Resident



1. for the purposes of this agreement reference to the expression "any person with

resident in one Contracting State "person under the legislation of

This State is taxable there because of domicile, residence, place

for management or other similar circumstances. The expression

However, it does not include a person who is liable to tax in that State

only on income from sources in that State.



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

both of the Contracting States, is determined his residence as follows:



a) He shall be deemed to have established in the State where he has a home that

permanently available to him. If he has such a property in

both States, he shall be deemed to be a resident of the State with which his

personal and economic relations are the strongest (Centre for

life interests).



(b)) if it cannot be settled in the State he has the Centre of its

living or if he's not in either State housing

Permanent stands at his disposal, he is deemed to be resident in the State

where he usually resides.



(c)) if he usually resides in both States, or if he is not allowed

permanently in any of them, he shall be deemed to be a resident of the State in which he is

citizens.



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

in one of them, the competent authorities of the Contracting

States the question by mutual agreement.



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

is a resident of both Contracting States, the person concerned shall be deemed to have

a resident of the State in which its place of effective management.



Article 5

Permanent establishment



1. for the purposes of this agreement reference to the expression "fixed

establishment '' a fixed place of business, from which

a business is wholly or partly carried on.



2. The term "permanent establishment" includes especially



a) place of business management,



b) branch,



c) offices,



d) factory,



e) workshop, and



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

the extraction of natural resources.



3. place of construction, construction or installation activities are

a permanent establishment only if the operation lasts more than six months.



4. Notwithstanding the preceding provisions of this article shall be deemed to

the term "permanent establishment" shall not include



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

or disclosure of the company belonging to 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

to engage in other activities of the undertaking of preliminary or

Deputy art,



f) holding of fixed place of business exclusively for the

combining the activities listed in paragraphs a)--e), during

provided that all the activities from the Permanent

place of business because of this combination is the

preparatory or auxiliary character.



5. If a person, who is not such independent representative at which point 6

applied, works for a company and of a Contracting State has

and there are regularly uses full power to conclude contracts in the company's

name, considered this company--notwithstanding the provisions of paragraphs 1

and 2--to have a permanent establishment in that State in respect of each activity

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

the activities of this person conducts are limited to such as are specified in the

paragraph 4 and which--if it were performed from a fixed place of

business activities--would not make this fixed place of

business activities in a permanent establishment under the provisions of the said

paragraph.



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

only on the basis that the company is doing business in this State

through the intermediary of brokers, Commissioner or other independent

Representative, provided that such person thereby carries out its

customary business practices.



7. the fact that a company resident in a Contracting State

controls or is controlled by a company resident in the other

Contracting State or by a company doing business in

the other State (either from a permanent establishment or otherwise),


does 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 by

real estate (in that included income from agriculture and forestry) situated

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



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

the law of the Contracting State in which the property is situated.

The term includes, however, always accessory to immovable property, live

and kill the equipment in agriculture and forestry, rights to which the

the provisions of civil law relating to immovable property apply, buildings,

tenancies of immovable property and rights to changeable or fixed

remuneration for the use of, or the right to use the mineral deposit,

source or another natural resource. Ships, boats and aircraft is not considered to

be real property.



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

immediately use, through rental or other use of the fixed

property.



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

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

at independent professional activities.



Article 7

Income from operating



1. the Income of an enterprise of a Contracting State to acquire,

shall be taxable only in that State unless the enterprise carries on business in the

the other Contracting State through permanent establishment situated there. If

the company carries on business has just given way, the company's income

be taxed in the 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, are entered, if

not the provisions of paragraph 3 shall give rise to another, in each Contracting

the State of the permanent establishment the income that it can be assumed that

establishment would have acquired if it remained an independent company,

as operated by the same or a similar nature in the same or

similar conditions and independently completed the business with the companies to

which the establishment belongs.



3. In determining permanent establishment income shall be allowed a deduction for

expenditure incurred for the permanent establishment, including included

expenditure for management and public administration, whether

expenditure incurred in the State in which the permanent establishment is situated

or elsewhere.



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

State used shall be determined on the basis of a distribution of the company's entire

income of the various parts of the company, prevent the provisions of paragraph

2 not in that Contracting State taxable income

is determined by such a procedure. The allocation method used shall

However, be such that the result is consistent with the principles set out in this

article.



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

purchase of goods through the Agency of the permanent establishment of the enterprise.



6. for the purposes of the preceding paragraphs, income that is determined

attributable to the permanent establishment by the same procedure from year to year,

unless good and sufficient reasons causing the other.



7. Included in income by operating income which are dealt with specifically in other

articles of this agreement, the provisions of those articles shall not be affected by

the rules of the present article.



Article 8

Sea and air transport



1. income as a company of a Contracting State acquires by

the use of ships or aircraft in international traffic shall be taxable

only in that Contracting State.



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

through participation in a pool, a joint business or an

international operating agency.



3. Notwithstanding the preceding provisions, income from shipping in

international traffic, which is acquired by companies or partnerships with

resident in Cyprus whose capital to more than 25% are mastered, directly or

indirectly by the people who do not live in Cyprus, are taxed in Sweden.

However, this does not apply if the company or trading company shows that

the income is subject to the Cypriot tax which would have been paid on

such income if the tax was calculated without observance of the provision

identical with or similar provisions of the at the signing

This agreement, applicable law on Merchant Shipping (tax provisions).



4. as regards the income acquired by the Danish, Norwegian and Swedish

the air transport Consortium Scandinavian Airlines System (SAS) be applied

the provisions of paragraph 1 only in terms of the proportion of income that

corresponds to the percentage of the Consortium held by AB Aerotransport (ABA),

the Swedish part owner of Scandinavian Airlines System (SAS).



Article 9

Companies with associated enterprises



1. In cases where the



a) an enterprise of a Contracting State participates directly or indirectly in

the management or monitoring of an enterprise of the other Contracting

State or own part in this undertaking, or



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

monitoring of an enterprise of a Contracting State as an

business in the other Contracting State, or owns part of both these

corporate capital, observed the following.



If between businesses in terms of trade relations or financial

relations agreed upon or prescribed conditions, which differ from those

would have been agreed between independent companies, all

income, that without such conditions would have been the one company

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

included in this corporate income and taxed in accordance

thereby.



2. In cases where the income, for which an enterprise of a Contracting State

subject to tax in that State, also be included in the income of an enterprise in the

other Contracting State and taxed accordingly, in

that other State and the income so included is such that

would have established the company in the other State if the conditions

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

between independent enterprises, then the first State

implement the proper adjustment of the amount of tax levied for

income in that State. for the observance of the other provisions of such adjustment

in this agreement and the competent authorities of the Contracting States

If necessary, consult with each other.



Article 10

Dividend



1. Dividends paid by a company resident in a Contracting State to the person

resident in the other Contracting State may be taxed in that

other State.



2. Dividends may be taxed in the Contracting State

which the company paying the dividends is a resident, according to the legislation of

that State, but if the recipient is entitled to the dividend tax may not

exceed



a) 5 per cent of the gross amount of the dividends if the beneficial owner of

the dividends is a company (other than a partnership) which directly

mastered at least 25 percent of the paying company's capital;



b) 15 per cent of the gross amount of the dividends in all other cases.



The competent authorities of the Contracting States shall meet

agreement on the way to implement these limits.



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

the dividend is paid.



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

mining shares, stiftarandelar or other rights, not being

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

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

is resident for tax purposes be treated as income of the

shares.



4. As long as any withholding tax on dividends not collected in Cyprus, is,

Notwithstanding the provisions of paragraph 2, dividends paid by companies with

resident in Cyprus to a resident of Sweden excluded from each

tax levied in Cyprus in addition to the tax on the profit of the

the dividend is paid. A natural person resident in Sweden is

eligible to regain the Cypriot tax which expired on the profit of the

the dividend will be paid to the extent that the tax exceeds that which he himself

would have had to pay in Cyprus.



5. Dividends paid by a company resident in Cyprus to resident companies

Sweden shall, notwithstanding the provisions of paragraph 1, be exempt

from taxation in Sweden to the extent that the dividends would have been

exempt from taxation under Swedish law if both companies had been

Swedish companies. Such exemption is granted, however, only



(a)) of the profit out of which the dividends are paid subject to the normal

Cypriot income tax for companies or another equivalent

income tax, or



(b)) the dividend paid by a company resident in Cyprus solely

or almost exclusively consists of dividends which this company

during the year or previous years received on shares or

shares, which it holds in a company resident in a third State,

and what would have been exempt from Swedish tax if the shares

or shares on which the dividends are paid, had held directly by

company domiciled in Sweden.



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

entitled to dividends is a resident of a Contracting State and carries on

on business in the other Contracting State, of which the company paying the

dividends is a resident, from where the permanent establishment situated or exercises

independent professional activities in the other State from where located


permanent device, and the proportion due to the dividend payment

paid owns truly connected with the permanent establishment or the

permanent device. In such cases, apply the provisions of

Article 7 or article 14.



7. If the company resident in a Contracting State receives income from

the other Contracting State, that other State may not tax

dividend that the company pays, except to the extent that the dividend will be paid to

a resident of that other State or insofar as the amount due

out of which the dividends are paid owns truly connected with a permanent establishment

or permanent device in that other State, nor tax

the company's undistributed profits, even if the dividend or non

distributed profits consists wholly or partly of income arising in

that other State.



Article 11

Interest rate



1. interest, stemming from a Contracting State and paid to the

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

that other State.



2. interest may also be taxed in the Contracting State of

which it was derived, according to the laws of that State, but if the recipient

is entitled to the interest, the tax does not exceed 10% of the interest

gross amount. The competent authorities of the Contracting States

shall reach agreement on the way to implement this restriction.



3. Notwithstanding the provisions of paragraph 2, interest arising from the

one Contracting State and received by the other Contracting

the Government of the State, its political subdivisions and local authorities

therein included, National Bank or State financial institution be exempt

from tax in the first-mentioned Contracting State.



4. For the purposes of paragraph 3, the terms "Bank" and "State

financial institution "as follows:



a) in Cyprus:



1) Cyprus ' National Bank and



2) State financial institution, the competent authorities of the

Contracting States have agreed,



b) in Sweden:



1) Swedish national debt Office and Sveriges riksbank, or



2) State financial institution, the competent authorities of the

Contracting States agreed.



5. The term "interest" shall be understood in this article the income of every kind of

the claim, whether secured by mortgage on immovable property or

not and either the right to participate in the debtor's profits or

do not. The term refers to the particular income from securities, issued

by the State, and income from bonds or debentures, therein included

premiums and benefits pertaining to such securities,

bonds or debentures; Penalty charge for late payment

However, it is not considered as interest for the purpose of this article.



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

the right to interest is resident in a Contracting State and carries on

on business in the other Contracting State, from which the interest arises,

from where the permanent establishment situated or exercising independent

professional activities in the other State from where located permanently

device, as well as the claim in respect of which the interest is paid owns real

connected with the permanent establishment or the permanent devices.

In such cases, apply the provisions of article 7 or article

14.



7. interest shall be deemed to arise from a Contracting State where the payer is the

the State itself, a political subdivision, local authority or person with

a resident of this State. If, however, the person paying the interest,

either he is domiciled in a Contracting State or not, in a

Contracting State has a permanent establishment or a permanent device in

the context of which the debt arose on which the interest is paid, and

the interest rate borne by the permanent establishment or the Permanent

the device is deemed to be the rate obtained from the State in which the Permanent

establishment or permanent device, see.



8. By reason of a special relationship between the payer and the

is entitled to the interest or between both of them and any other person

the amount of the interest, having regard to the debt claim in respect of which the interest is paid,

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

who is entitled to the rate of such relations do not exist,

the provisions of this article shall apply only to the last-mentioned amount. In

such cases are taxable surplus amount in accordance with the laws of

Each Contracting State shall, subject to compliance with other provisions of

This agreement.



Article 12

Royalty



1. Royalty, as derived from a Contracting State and paid to the

a resident of the other Contracting State, be taxable only in

the other State, if the person concerned has the right to royalties.



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

received as compensation for the use of, or the right to

use the copyright of literary, artistic or scientific

work, including cinematograph films and films or recording for radio-

or television broadcasting, any patent, trade mark, design or model,

drawing, secret recipe or secret manufacturing process or for

information concerning industrial, commercial or

scientific nature.



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

the royalty is domiciled in a Contracting State, carries on business in the

other Contracting State, from which the royalty arises, from which

permanent establishment situated or exercising independent professional activities in

the other State from where located permanent device, as well as the

right or property in respect of which the royalties are paid owns real

connected with the permanent establishment or the permanent devices.

In such cases, apply the provisions of article 7 or article

14.



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

entitled to the royalties 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 paid, exceeds the amount which would

be agreed between the payer and the beneficial owner of royalties if the

such links do not exist, the provisions of this

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

excess amounts in accordance with the legislation of each Contracting

State in accordance with the other provisions of this agreement.



Article 13

Capital gain



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

alienation of such immovable property referred to in article 6 and

is situated in the other Contracting State or because of

transfer of shares in a company, whose main assets consist

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



2. Gains from the alienation 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 permanent device to exercise

independent professional activity, which a resident of a Contracting

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

the same is true of State. gains from the alienation of such a permanent

establishment (alone or with the whole enterprise) or of

such a permanent device.



3. Profit, as a person resident in one Contracting State acquires at

alienation of ships or aircraft used in

international traffic, or movable property which are attributable to

the use of such ships or aircraft, shall be taxable only in this

State.



As regards the profit acquired by consortium of Scandinavian Airlines

System (SAS) the provisions of this paragraph apply only in respect of

the part of the profits as corresponds to the participation in the consortium which is held

by AB Aerotransport (ABA), the Swedish partner of Scandinavian Airlines

System (SAS).



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

paragraphs 1, 2 and 3 shall be taxable only in the Contracting State in which the

alienator is a resident.



5. In the case where a natural person has been resident in one Contracting

State and a resident of the other Contracting State affects

the provisions in paragraph 4 is not the first State the right to tax

such gains from the alienation of property in which such a person receives

at some point during the seven years following the

the person has ceased to be resident in that State.



Article 14

Independent professional activities



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

through the exercise of profession or other independent activity,

shall be taxable only in that State unless he in the other Contracting

the State has a permanent device, which are regularly at his

disposal to pursue the activity. If he has such a permanent

device, the income taxed in the other State but only so much

of them as is attributable to that permanent device.



2. The expression "liberal profession '' includes especially independent

scientific, literary and artistic activities, educational and

teaching activities as well as 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 and 20 prompts

other, taxable wages and other similar remuneration (with the exception of

pension), resident of a Contracting State carries on

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


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

receive compensation received for work are taxed there.



2. Notwithstanding the provisions of paragraph 1 shall be taxable compensation, which

person resident in one Contracting State receives for work performed

in the other Contracting State, only in the first-mentioned State if



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

that total does not exceed 183 days during a 12-month period,

and



(b)) the compensation is paid by or on behalf of employers who do not have

a resident of the other State, and



c) compensation does not affect the permanent establishment or habitual

device which the employer has in the other State.



3. Notwithstanding the preceding provisions of this article, remuneration

for the work, which is carried out on board the ship or aircraft used in

international traffic of enterprises of a Contracting State, shall be taxable in the

This state. where a resident of Sweden receives income from work,

which is performed on board an aircraft used in international

traffic by the Consortium Scandinavian Airlines System (SAS), taxed

income only in Sweden.



Article 16

Directors ' fees



Directors ' fees and other similar remuneration, as a resident of

a Contracting State receives as a member of the Board of directors or

other similar bodies in companies resident in the other Contracting

the State, may be taxed in that other State.



Article 17

Artists and athletes



1. Notwithstanding the provisions of articles 14 and 15, income,

person resident in one Contracting State acquires by their

personal business in the other Contracting State in the capacity of

artist, such as a theatre or movie actor, radio or

television artist, or a musician, or athlete, taxed in this

other State.



2. In cases where the income through personal business, as an artist or

athlete exercising as such, do not become the property of the artist or

the athlete himself without another person, that income may, notwithstanding the

the provisions of articles 7, 14 and 15, be taxed in the Contracting

State of the artist or athlete exercising activities.



Article 18

Public service



1. a) Compensation (except for retirement), paid for by a

Contracting State, its political subdivisions or local

authorities to the natural person on the basis of the work carried out in this

the State, its political underavdelningars or local authorities

service, shall be taxable only in that State.



b However, such remuneration shall be taxable only) in the second

Contracting State, if the work is performed in that State and the individual in

question is domiciled in this State and



1) is a national of that State, or



2) were not allowed to live in this State solely to perform the work.



2. a) Pensions, paid by, or out of funds created by, a

Contracting State, its political subdivisions or local

authorities to the natural person on the basis of the work carried out in this

the State, its political underavdelningars or local authorities

service, shall be taxable only in that State.



(b) However, such pension shall be taxable) only in the other Contracting

the State, if the person concerned is domiciled or is a national of that State.



3. the provisions of articles 15, 16 and 20 shall apply to remuneration and

pension payable on the basis of work carried out in connection with business

carried on by a Contracting State, its political subdivisions

or local authorities.



Article 19

Students



A student or business trainee who is, or immediately before

stay in a Contracting State a resident of the other

Contracting State and residing in the former Contracting

State exclusively for their education or training, is not taxed

in this Contracting State for



a) amounts payable to him from sources outside that State for

his living, teaching or training, and



b) income from work performed in that Contracting State, if

income is not in any tax year exceeds 10 000 Swedish

dollars or the equivalent in Cyprus pounds.



The exemption provided for in (b) above) shall be allowed only for such time as is reasonably

required to complete the training or practice, but not in

no case refer to longer period than seven consecutive years.



Article 20

Other income



1. income as a resident of a Contracting State acquires and

which are not dealt with in the foregoing articles of this Agreement shall be taxable only

in this State, regardless of where the income is derived.



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

income from immovable property referred to in paragraph 2 of article 6, if the recipient of the

income is domiciled in a Contracting State, carries on business in

the other Contracting State from where the permanent establishment situated or

exercising independent professional activities in the other State from where located

permanent device, and the right or property due to

the income paid own actual relation to the Permanent

the establishment or the permanent devices. In such a case

apply the provisions of article 7 or article 14.



3. income which are not dealt with in the foregoing articles of this agreement,

as a resident of a Contracting State acquires and derived

from the other Contracting State, may, notwithstanding the provisions

in paragraphs 1 and 2, be taxed in that other State.



4. income referred to in this article shall be deemed to arise from a

Contracting State, if the payer is that State itself, a political

Subdivision, local authority or resident of that State

or when income is paid under the social security legislation in

This state.



Article 21

The Elimination of double taxation



1. In Cyprus double taxation is avoided in the following manner:



(a)) in accordance with the provisions laid down in Cypriot legislation on tax credit

of foreign taxation, from Cypriot tax on income or

taxable capital gain derived from Sweden offset the

Swedish tax paid under Swedish law and in accordance with this

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

Cypriot tax, calculated without such a settlement, charged on such

income or taxable capital gain.



(b)) in cases where such income or taxable capital gain is

of dividends from a company established in Sweden to a company

resident in Cyprus, which directly owns at least 25% of the Swedish company's

capital, be included in the settlement (except every Swedish tax on

the dividend) the Swedish tax payable by the company paying dividends pay to their

income and which is attributable to this capital.



2. In Sweden, double taxation shall be avoided as follows:



a) where a resident of Sweden acquires income according to

Cypriot legislation and in accordance with the provisions of this agreement

may be taxed in Cyprus, Sweden, unless the provisions of (b))

below, causing the other, taking into account the provisions in Swedish

relating to settlement of foreign tax--as it can get

to change from time to time without changing the general principle set out

This change--from this person's Swedish income tax set off an amount

corresponding to the Cypriot tax paid on this income.



b) where a resident of Sweden claiming income according to

the provisions of article 7 or article 14 may be taxed in Cyprus,

Sweden shall exempt the income from tax, provided that the

most of the income from the permanent establishment or the

Permanent devices derived from activities other than the management of

securities or other similar property and the activities in question

carried out in Cyprus from the permanent establishment or the Permanent

the device.



(c)) where a resident of Sweden claiming income according to

the provisions of this Agreement shall be taxable only in Cyprus or shall

shall be exempt from Swedish tax according to point (b)), Sweden, at

the determination of the tax rate for Swedish progressive tax, take into account the

income which shall be taxable only in Cyprus and is exempt from

Swedish tax.



(d)) at the reduced rate of tax referred to in paragraph (a)) shall,



1) in cases where dividends are exempt from tax in Cyprus in addition to the tax

based on the company's profits or income, or taxed in Cyprus with

a tax rate of less than 20% of the gross amount of the dividends, the

Cypriot tax constitute 20% of the gross amount of the dividends;



2) in cases where such a rate at which the provisions of article 11, paragraph 2

applied in Cyprus are taxed at a rate of less than 15% of

gross amount of this allowance, the Cypriot tax constitute 15% of the

gross amount of the interest.



The provisions of this paragraph for the first seven years during which this

Agreement shall apply. The competent authorities shall consult each other

to determine whether this period shall be extended.



3. In cases where pursuant to the provision of this agreement, taxation of income

or taxable capital gain be alleviated in one Contracting State

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

Contracting State is taxed on such income or taxable

capital gain to the extent that it is transferred to or received in that

other Contracting State and not to its full amount, the

tax relief under this agreement be provided for in the first

Contracting State shall refer to only the portion of the income or the

taxable capital gain that is transferred to or received in


the other Contracting State.



4. For the purposes of this article, income accruing to a

resident of a Contracting State which are taxed in the

other Contracting State in accordance with this agreement, be deemed to originate

from sources in that other State.



Article 22

Prohibition of discrimination



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

Contracting State be subject to taxation or

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

taxation and related requirements that citizens in this second

State in the same circumstances are or may be subject to. Without barriers

the provisions of article 1 shall apply this provision also on the person

who is not domiciled in a Contracting State, or in both

Contracting States.



2. the taxation on a permanent establishment which businesses of a Contracting

State has in the other Contracting State, that other State

not be less advantageous than the taxation of the company in this second

State, that carries out activities of the same kind.



This provision is not considered to entail the obligation of a Contracting

State to grant a resident of the other Contracting State

such personal deductions for taxation or tax exemptions

or reductions because of marital or dependent

against the family allowed resident of their own State.



3. Except where the provisions of article 9, paragraph 1, article 11

paragraph 8 or article 12 paragraph 4 shall apply, interest, royalties and other

payment from the company of a Contracting State to a resident

in the other Contracting State are deductible in determining the

taxable income of such company on the same terms and conditions as

payment to a resident of the first State. At the same

way is the debt as a company of a Contracting State has to person with

resident in the other Contracting State tax deductible in determining the

of such company's taxable wealth under the same conditions as

debt to a resident of the first State.



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

or controlled, directly or indirectly, by one or more persons

resident in the other Contracting State, shall not in

first State become subject to taxation or

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

taxation and related requirements as other similar undertakings in

the first State are or may be subjected.



5. Notwithstanding the provisions of article 2 shall apply the provisions of

the present article on the taxes of every kind and nature.



Article 23

The procedure for the mutual agreement



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

Contracting States took measures to him causes or

will lead to taxation contrary to the provisions of this

Agreement, he may, without prejudice to his right to make use of the

legal remedies in the domestic legal system of those States, present

matter to the competent authority of the Contracting State in which he has

domicile or, in the case of application of article 22, paragraph 1, of the

Contracting State of which he is a national. The matter shall be submitted within

three 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 not

can bring about a satisfactory resolution, the authority

resolve the matter by mutual agreement with the competent

authority of the other Contracting State for the purpose of avoiding

taxation contrary to the agreement. Agreement

implemented notwithstanding the time limits in the Contracting States

internal legislation.



3. the competent authorities of the Contracting States shall by

mutual agreement, seek to determine difficulty or doubt as

arise regarding the interpretation or application of the agreement. They can

also consult in order to eliminate double taxation in cases not

covered by the agreement.



4. the competent authorities of the Contracting States may enter into

direct communication with each other to implement the agreement in the cases

specified in the preceding paragraphs.



Article 24

Exchange of information



1. the competent authorities of the Contracting States shall exchange

such information as is necessary to implement the provisions of

This agreement, or in the internal law of the Contracting States in

question about the taxes covered by the agreement insofar as the taxation under

This legislation is not contrary to the agreement. The exchange of information

is not restricted by article 1. Information which a Contracting State

received shall be treated as secret in the same manner as information,

obtained in accordance with the internal law of that State, and may

be disclosed only to persons or authorities (including courts therein

and management bodies) which defines, collects or collect the taxes

covered by the agreement or dealing with criminal charges or complaints in the field of

These taxes. Such persons or authorities shall use the

the information only for such purposes. They may disclose the information in

public trial or in judicial decisions.



2. the provisions of paragraph 1 is not considered to entail the obligation for an

Contracting State to



a) take administrative measures derogating from the legislation and

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

Contracting State,



b) provide information that is not available under laws or

the usual administrative practice in this State or in the

other Contracting State,



c) supply information which would disclose any commercial, industrial,

commercial or professional secret or of a commercial project.

process or information, whose surrender would be contrary to

General considerations (public policy).



Article 25

Diplomatic representatives and consular officials



The provisions of this Agreement shall not affect the privileges in taxation

which, according to the General rules of international law or the provisions of the Special

agreements apply diplomatic representatives or consular

officials.



Article 26

Date of entry into force



1. This agreement shall be ratified and the instruments of ratification documents shall

are exchanged in London as soon as possible.



2. the agreement shall enter into force with the exchange of the ratification documents

and its provisions apply to income that is acquired on 1 January

1988 or later.



Article 27

Termination



1. this Agreement shall remain in force until terminated by a Contracting

State. Each Contracting State may terminate the agreement at any time

After the expiry of a period of five years from the date of

entry into force, provided that notice of termination has been

by diplomatic means at least six months in advance. In the event of such

termination agreement ceases to have effect on income acquired from and

1 January of the year following after it on which denunciation

took place.



In witness whereof the undersigned, being duly

authorised, have signed this agreement and provided the same with their

seal.



Done at London on 25 October 1988, in duplicate, in English

the language.



For The Kingdom Of Sweden

Leif Leifland



For The Republic Of Cyprus

Tassos Panayides