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

tax evasion with respect to taxes on income as Sweden and

Japan signed on January 21, 1983, in the version in this

by the Protocol amending the agreement as

signed on 19 February 1999 respectively on december 5

2013, to be valid as law in this country. The agreement by

protocols modified wording is the intake as an annex to this

team. Law (2014:374).



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

involves restriction of the tax liability in Sweden that would otherwise

exist.



3 repealed by law (2011:1313).



paragraph 4 of Article 8 shall apply in respect of income acquired by

Scandinavian Airlines System (SAS) through the use of

aircraft, but only in respect of so much of this

income that is attributable to the Swedish part owner.



If resident in Sweden receives income from work

performed on board the aircraft used in international

traffic by the Scandinavian Airlines System (SAS) be applied

the provisions of article 15(1) and (2) on such income.

Law (2014:374).



Transitional provisions



1999:891



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



2. This Act shall apply



(a)) in respect of withholding taxes: the amount paid or

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

the law enters into force, or later,



(b)) in respect of other taxes on income: fiscal years

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

enters into force, or later.



3. Through law repeals Regulation (1983:769) if

double taxation treaties between Sweden and Japan.



The repealed Regulation shall continue to apply



(a)) in respect of withholding taxes: the amount paid or

credited before 1 January of the calendar year immediately following the year in

When the Act comes into force,



(b)) in respect of other taxes on income: fiscal years

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

the law comes into force.



2014:374



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



2. this law shall apply in the case of



a) withholding taxes, on amounts paid or tillgodoförs the

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

enters into force, or later,



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

tax year that begins on 1 January of the year following

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



c) arbitration under article 24 paragraphs 5 to 7 of the

Agreement, from the date of entry into force of this Act

for



– cases submitted before the date of the Act come into force;

in such a case, however, may not be subject to

arbitration sooner than three years after the entry into force,

and



– cases coming in after the entry into force of this law,

and



d) information exchange under article 25 of the agreement and aid

with the recovery as referred to in article 25A of the agreement, on request

produced on the date of entry into force of the Act or later

regardless of which year the tax claim is

attribute.



Annex Convention between Australia and Japan for the Avoidance of

Double Taxation and the Prevention of Fiscal Evasion with

Respect to Taxes on Income



The Government of Canada and the Government of Japan,



Desiring to conclude a new Convention for the avoidance of

double taxation and the prevention of fiscal evasion with

respect to taxes on income,



Have agreed as follows:



Article 1



Personal scope



This Convention shall apply to persons who are residents of

one or both of the Contracting States.



Article 2



Taxes covered



1. The taxes which are the subject of this Convention are:



(a) In Japan:



(i) the income tax;



(ii) the corporation tax;



(iii) the special income tax for reconstruction;



(iv) the special corporation tax for reconstruction; and



(v) the local inhabitant taxes



(hereinafter referred to as "Japanese tax");



(b) In Sweden:



(i) the national income tax;



(ii) the withholding tax on dividends;



(iii) the income tax on non-residents;



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

and



(v) the municipal income tax



(hereinafter referred to as "Swedish tax").



2. This Convention shall also apply to any identical or

substantially similar taxes, whether national or local, which

are imposed after the date of signature of this Convention in

addition to, or in place of, those referred to in paragraph

1. The competent authorities of the Contracting States shall

notify each other of any substantial changes which have been

made in their respective taxation laws within a reasonable

period of time after such changes.



Article 3



General definition



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

otherwise requires:



(a) the term "Japan", when used in a geographical sense,

means all the territory of Japan, including its territorial

Sea, in which the laws relating to Japanese tax are in force,

and all the area beyond its territorial sea, including the

seabed homepage and subsoil thereof, over which Japan has jurisdiction

in accordance with international law and in which the laws

relating to Japanese tax are in force;



(b) the term "Sweden" means the Kingdom of Sweden and

includes any area outside the territorial sea of Sweden

within which, in accordance with international law and the

the laws of Hong Kong the rights of Canada with respect to the

exploration and exploitation of the natural resources on the

sea-bed or in its subsoil may be exercised;



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

Contracting State "mean Japan or Sweden, as the context

requires;



(d) the term "tax" means Japanese tax or Swedish tax, as the

context requires;



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

any other body of persons;



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

which is treated as a body corporate for tax purposes;



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

"enterprise of the other Contracting State" mean respectively

an enterprise carried on by a resident of a Contracting State

and an enterprise carried on by a resident of the other

Contracting State;



(h) the term "nationals" means all individuals possessing the

nationality of either Contracting State and all juridical

persons created or organized under the laws of either

Contracting State and all organizations without juridical

personality treated for the purposes of tax of either

Contracting State as juridical persons created or organized

under the laws of that Contracting State;



(i) the term "international traffic" means any transport by

a ship or aircraft operated by an enterprise of a Contracting

State, except when the ship or aircraft is operated solely

between places in the other Contracting State;



(j) the term "competent authority" means:



(i) in Japan, the Minister of Finance or his authorized

representative;



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

representative or the authority which is designated as a

competent authority for the purposes of this Convention;



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

business; and



(l) the term "business" includes the performance of

professional services and of other activities of an

independent character.



2. As regards the application of this Convention by a

Contracting State, any term not defined therein shall, unless

the context otherwise requires, have the meaning which it has

under the laws of that Contracting State concerning the taxes

to which this Convention applies.



Article 4



Resident



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

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

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

his domicile, residence, place of head or main office, place

of management or any other criterion of a similar nature, and

also includes that Contracting State and any governmental

body or agency, political subdivision or local authority

thereof and a pension fund as referred to in subparagraph (d)

of paragraph 7 of Article 21A. This term, however, does not

include any person who is liable to tax in that Contracting

State in respect only of income from sources in that

Contracting State.



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

individual is a resident of both Contracting States, then his

status shall be determined as follows:



(a) he shall be deemed to be a resident only of the

Contracting State in which he has a permanent home available

to him; If he has a permanent home available to him in both

Contracting States, he shall be deemed to be a resident only

of the Contracting State with which his personal and economic

relations are closer (centre of vital interests);



(b) if the Contracting State in which he has his centre of

vital interests cannot be determined, or if he has not a

a permanent home available to him in either Contracting State,

He shall be deemed to be a resident only of the Contracting

State in which he has an habitual abode;



(c) if he has an habitual abode in both Contracting States or

in neither of them, he shall be deemed to be a resident only

of the Contracting State of which he is a national;



(d) if he is a national of both Contracting States or of

Neither of them, the competent authorities of the Contracting

States shall settle the question by mutual agreement.



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

other than an individual is a resident of both Contracting

States, then the competent authorities of the Contracting


States shall endeavour to determine by mutual agreement the

Contracting State of which that person shall be deemed to be

a resident for the purposes of this Convention. In the

absence of such agreement, such person shall not be entitled

to any reduction or exemption from tax provided by this

Convention.



Article 5



Permanent establishment



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

establishment "means a fixed place of business through which

the business of an enterprise is wholly or partly carried

on.



2. The term "permanent establishment" includes especially:



(a) a place of management;



(b) a branch;



(c) an office;



(d) a factory;



(e) a workshop; and



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

of extraction of natural resources.



3. A building site or construction or installation project

constitutes a permanent establishment only if it load more

than twelve months.



4. Notwithstanding the provisions of the preceding paragraphs

of this Article, the term "permanent establishment" shall be

deemed not to include:



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

display or delivery of goods or merchandise belonging to the

Enterprise;



(b) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of

storage, display or deliver;



(c) the maintenance of a stock of goods or merchandise

belonging to the enterprise solely for the purpose of

processing by another enterprise;



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

the purpose of purchasing goods or merchandise or of

collecting information, for the enterprise;



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

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

activity of a preparatory or auxiliary character; and



(f) the maintenance of a fixed place of business solely for

any combination of activities mentioned in sub paragraphs (a)

to (e), provided that the overall activity of the fixed place

of business resulting from this combination is of a

preparatory or auxiliary character.



5. Notwithstanding the provisions of paragraphs 1 and 2,

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

to whom the provisions of paragraph 6 apply – is acting on

behalf of an enterprise and has, and habitually exercises, in

a Contracting State an authority to conclude contracts in the

name of the enterprise, that enterprise shall be deemed to

have a permanent establishment in that Contracting State in

respect of any activities which that person undertakes for

the enterprise, unless the activities of such person are

limited to those mentioned in paragraph 4 which, if exercised

through a fixed place of business, would not make this fixed

place of business a permanent establishment under the

the provisions of that paragraph.



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

establishment in a Contracting State merely because it

carries on business in that Contracting State through a

broker, general commission agent or any other agent of an

independent status provided that such persons are acting in

the ordinary course of their business.



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

Contracting State controls or is controlled by a company

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

carries on business in that other Contracting State (whether

through a permanent establishment or otherwise), shall not of

itself constitute either company a permanent establishment of

the other.



Article 6



Income from immovable property



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

immovable property situated in the other Contracting State

may be taxed in that other Contracting State.



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

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

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

the include property accessory to immovable property, livestock

and equipment used in agriculture and forestry, rights to

which the provisions of general law respecting landed

property apply, buildings, usufruct of immovable property and

rights to variable or fixed payments as consideration for the

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

and other natural resources; ships and aircraft shall not be

regarded as immovable property.



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

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

the form of immovable property.



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

the income from immovable property of an enterprise.



Article 7



Business profits



1. The profits of an enterprise of a Contracting State shall

be taxable only in that Contracting State unless the

the enterprise carries on business in the other Contracting State

through a permanent establishment situated therein. If the

the enterprise carries on business as aforesaid, the profits of

the enterprise may be taxed in that other Contracting State

but only so much of them as is attributable to that permanent

Re-establishment.



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

Enterprise of a Contracting State carries on business in the

other Contracting State through a permanent establishment

situated therein, there shall in each Contracting State be

attributed to that permanent establishment the profits which

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

separate enterprise engaged in the same or similar activities

under the same or similar conditions and dealing wholly

independently with the enterprise of which it is a permanent

Re-establishment.



3. In determining the profits of a permanent establishment,

There shall be allowed as deductions expenses which are

incurred for the purposes of the permanent establishment,

including executive and general administrative expenses so

incurred, whether in the Contracting State in which the

permanent establishment is situated or elsewhere.



4. No profits shall be attributed to a permanent

establishment by reason of the mere purchase by that

permanent establishment of goods or merchandise for the

Enterprise.



5. For the purposes of the provisions of the preceding

paragraphs of this Article, the profits to be attributed to

the permanent establishment shall be determined by the same

method year by year unless there is good and sufficient

reason to the contrary.



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

separately in other Articles of this Convention, then the

the provisions of those Articles shall not be affected by the

the provisions of this Article.



Article 8



Shipping and air transport



1. Profits from the operation of ships or aircraft in

international traffic carried on by an enterprise of a

Contracting State shall be taxable only in that Contracting

State.



2. In respect of the operation of ships or aircraft in

international traffic carried on by an enterprise of a

Contracting State, that enterprise, if an enterprise of

United States, shall be exempt from the enterprise tax in Japan, and

If an enterprise of Japan, shall be exempt from any tax

similar to the enterprise tax in Japan which may hereafter be

imposed in Sweden.



3. The provisions of the preceding paragraphs of this Article

shall also apply to profits from the participation in a pool,

a joint business or in an international operating agency.



Article 9



Associated enterprises



1. The Where clause



(a) an enterprise of a Contracting State participates

directly or indirectly in the management, control or capital

of an enterprise of the other Contracting State, or



(b) the same persons participate directly or indirectly in

the management, control or capital of an enterprise of a

Contracting State and an enterprise of the other Contracting

State,



and in either case conditions are made or imposed between the

the two enterprises in their commercial or financial relations

which differ from those which would be made between

independent enterprises, then any profits which would, but

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

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

be included in the profits of that enterprise and taxed

accordingly.



2. Where a Contracting State includes, in accordance with the

the provisions of paragraph 1, in the profits of an enterprise of

that Contracting State – and taxes accordingly – profits on

which an enterprise of the other Contracting State has been

charged to tax in that other Contracting State and where the

competent authorities of the Contracting States agree, upon

consultation, that all or part of the profits so included are

profits which would have accrued to the enterprise of the

the first-mentioned Contracting State if the conditions made

between the two enterprises had been those which would have

been made between independent enterprises, then that other

Contracting State shall make an appropriate adjustment to the

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

determining such adjustment, due regard shall be had to the

other provisions of this Convention.



Article 10



Dividends



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

Contracting State to a resident of the other Contracting

State may be taxed in that other Contracting State.



2. However, such dividends may also be taxed in the

Contracting State of which the company paying the dividends

is a resident and according to the laws of that Contracting

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

resident of the other Contracting State, the tax so charged

shall not exceed 10 per cent of the gross amount of the

dividends.



3. Notwithstanding the provisions of paragraph 2, dividends


shall not be taxed in the Contracting State of which the

company paying the dividends is a resident if the beneficial

owner of the dividends is a resident of the other Contracting

State and is a company (other than a partnership) that has

held, directly or indirectly, at least 10 per cent of the

voting power of the company paying the dividends for the

period of six months ending on the date on which entitlement

to the dividends is determined. For the purposes of this

paragraph, the term "partnership" does not include any entity

that is treated as a body corporate for tax purposes in a

Contracting State and is a resident of that Contracting

State.



4. The provisions of paragraphs 2 and 3 shall not affect the

taxation of the company in respect of the profits out of

which the dividends are paid.



5. The provisions of paragraph 3 shall not apply in the case

of dividends paid by a company which is entitled to a

deduction for dividends paid to its with in

computing its taxable income in the Contracting State of

which the company paying the dividends is a resident.



6. Notwithstanding the provisions of paragraph 1, dividends

paid by a company being a resident of Japan to a company

which is a resident of Sweden shall be exempt from Swedish

tax to the extent that the dividends would have been exempt

under the laws of Canada if both companies had been Swedish

companies. This exemption shall not apply unless the profits

out of which the dividends are paid have been subjected to

the normal corporation tax in Japan or an income tax

status thereto.



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

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

participating in profits, as well as income from other

corporate rights which is subjected to the same taxation

treatment as income from shares by the taxation laws of the

Contracting State of which the company making the

the distribution is a resident.



8. The provisions of paragraphs 1, 2, 3, 4 and 5 shall not

apply if the beneficial owner of the dividends, being a

the resident of a Contracting State, carries on business in the

other Contracting State of which the company paying the

dividends is a resident through a permanent establishment

situated therein and the holding in respect of which the

dividends are paid is effectively connected with such

permanent establishment. In such case the provisions of

Article 7 shall apply.



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

derives profits or income from the other Contracting State,

that other Contracting State may not impose any tax on the

dividends paid by the company, except insofar as such

dividends are paid to a resident of that other Contracting

State or insofar as the holding in respect of which the

dividends are paid is effectively connected with a permanent

establishment situated in that other Contracting State, nor

subject the company's undistributed profits to a tax on the

company's undistributed profits, even if the dividends paid

or the undistributed profits consist wholly or partly of

profits or income arising in that other Contracting State.



Article 11



Interest



1. Interest arising in a Contracting State and beneficially

owned by a resident of the other Contracting State shall be

taxable only in that other Contracting State.



2. Notwithstanding the provisions of paragraph 1, interest

arising in a Contracting State that is determined by

reference to receipts, sales, income, profits or other cash

flow of the debtor or a related person, to any change in the

the value of any property of the debtor or a related person or to

any dividends, partnership distribution or similar payment

made by the debtor or a related person, or any other interest

similar to such interest arising in a Contracting State, may

be taxed in the Contracting State in which it arises, and

According to the laws of that Contracting State, but if the

beneficial owner of the interest is a resident of the other

Contracting State, the tax so charged shall not exceed 10 per

cent of the gross amount of the interest.



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

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

mortgage and whether or not carrying a right to participate

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

Government securities and income from bonds or debentures,

including premiums and prizes attaching to such securities,

bonds or debentures, and all other income that is subjected

to the same taxation treatment as income from money lent by

the tax laws of the Contracting State in which the income

arises. Penalty charges for late payment shall not be

regarded as interest for the purposes of this Article. Income

dealt with in Article 10 shall not be regarded as interest

for the purposes of this Convention.



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

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

Contracting State, carries on business in the other

Contracting State in which the interest arises through a

permanent establishment situated therein and the debt-claim

in respect of which the interest is paid is effectively

connected with such permanent establishment. In such case the

the provisions of Article 7 shall apply.



5. Interest shall be deemed to arise in a Contracting State

When the payer is a resident of that Contracting State.

Where, however, the person paying the interest, whether he is

a resident of a Contracting State or not, has in a

Contracting State a permanent establishment in connection

with which the indebtedness on which the interest is paid was

incurred, and such interest is borne by such permanent

establishment, then such interest shall be deemed to arise in

the Contracting State in which the permanent establishment is

situated.



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

payer and the beneficial owner or between both of them and

some other person, the amount of the interest, having regard

to the debtclaim for which it is paid, exceeds the amount

which would have been agreed upon by the payer and the

beneficial owner in the absence of such relationship, the

the provisions of this Article shall apply only to the

last-mentioned amount. In such case, the excess part of the

payments shall remain taxable according to the laws of each

Contracting State, due regard being had to the other

the provisions of this Convention.



Article 12



Royalties



1. Royalties arising in a Contracting State and beneficially

owned by a resident of the other Contracting State shall be

taxable only in that other Contracting State.



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

payments of any kind received as a consideration for the use

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

or scientific work including cinematograph films and films or

tapes for radio or television broadcasting, any patent, trade

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

for information concerning industrial, commercial or

scientific experience.



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

beneficial owner of the royalties, being a resident of a

Contracting State, carries on business in the other

Contracting State in which the royalties arise through a

permanent establishment situated therein and the right or

property in respect of which the royalties are paid is

effectively connected with such permanent establishment. In

such case the provisions of Article 7 shall apply.



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

payer and the beneficial owner or between both of them and

some other person, the amount of the royalties, having regard

to the use, right or information for which they are paid,

exceeds the amount which would have been agreed upon by the

payer and the beneficial owner in the absence of such

relationship, the provisions of this Article shall apply only

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

of the payments shall remain taxable according to the laws of

Each Contracting State, due regard being had to the other

the provisions of this Convention.



Article 13



Capital gains



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

the alienation of immovable property referred to in Article 6

and situated in the other Contracting State may be taxed in

that other Contracting State.



2. Gains from the alienation of any property, other than

immovable property, forming part of the business property of

a permanent establishment which an enterprise of a

Contracting State has in the other Contracting State,

including such gains from the alienation of such a permanent

establishment (alone or together with the whole enterprise),

may be taxed in that other Contracting State.



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

the alienation of ships or aircraft operated in international

traffic and any property, other than immovable property,

pertaining to the operation of such ships or aircraft shall

be taxable only in that Contracting State.



Article 14 (Deleted)



Article 15



Dependant personal services



1. Subject to the provisions of Articles 16 and 18, salaries,

wages and other similar remuneration, other than a pension,

derived by a resident of a Contracting State in respect of an

employment shall be taxable only in that Contracting State

unless the employment is exercised in the other Contracting

State. If the employment is so exercised, such remuneration

as is derived therefrom may be taxed in that other

Contracting State.



2. Notwithstanding the provisions of paragraph 1,

remuneration derived by a resident of a Contracting State in

respect of an employment exercised in the other Contracting

State shall be taxable only in the first-mentioned

Contracting State if:




(a) the recipient is present in that other Contracting State

for a period or periods not exceeding in the aggregate 183

days in any twelve month period commencing or ending in the

the taxable year concerned; and



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

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



(c) the remuneration is not borne by a permanent

establishment which the employer has in that other

Contracting State.



3. Notwithstanding the provisions of the preceding paragraphs

of this Article, remuneration derived in respect of an

the employment exercised aboard a ship or aircraft operated in

international traffic by an enterprise of a Contracting State

may be taxed in that Contracting State.



Article 16



Directors ' fees



Directors ' fees and other similar payments derived by a

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

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

the other Contracting State may be taxed in that other

Contracting State.



Article 17



Artistes and athletes



1. Notwithstanding the provisions of Articles 7 and 15,

income derived by a resident of a Contracting State as an

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

television artiste, and a musician, or as an athlete, from

his personal activities as such exercised in the other

Contracting State, may be taxed in that other Contracting

State.



Such income shall, however, be exempt from the tax of that other

Contracting State if such activities are exercised by an

individual, being a resident of the first-mentioned

Contracting State, pursuant to a special programme for

cultural exchange agreed upon between the Governments of the

two Contracting States.



2. Where the income derived in respect of personal activities

exercised by an entertainer or an athlete in his capacity as

such accrues not to the entertainer or athlete himself but to

another person, that income may, notwithstanding the

the provisions of Articles 7 and 15, be taxed in the Contracting

State in which the activities of the entertainer or athlete

are exercised.



Such income shall, however, be exempt from tax in that

Contracting State if such income is derived from the

the activities exercised by an individual, being a resident of

the other Contracting State, pursuant to a special programme

for cultural exchange agreed upon between the Governments of

the two Contracting States and accrues to another person who

is a resident of that other Contracting State.



Article 18



Government services



1. (a) Remuneration, other than a pension, paid by a

Contracting State or a local authority thereof to an

individual in respect of services rendered to that

Contracting State or local authority thereof, in the

discharge of functions of a governmental nature, shall be

taxable only in that Contracting State.



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

other Contracting State if the services are rendered in that

other Contracting State and the individual is a resident of

that other Contracting State who:



(i) is a national of that other Contracting State; or



(ii) did not become a resident of that other Contracting

State solely for the purpose of performing the services.



2. (a) Any pension paid by, or out of funds to which

contributions are made by, a Contracting State or a local

authority thereof to an individual in respect of services

rendered to that Contracting State or a local authority thereof

shall be taxable only in that Contracting State.



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

Contracting State if the individual is a resident of, and a

national of, that other Contracting State.



3. The provisions of Articles 15, 16, 17 and 21 shall apply

to remuneration and pensions in respect of services rendered

in connection with a business carried on by a Contracting

The State or a local authority thereof.



Article 19



The student's



Payments which a student or business apprentice who is or was

immediately before visiting a Contracting State a resident of

the other Contracting State and who is present in the

the first-mentioned Contracting State solely for the purpose of

his education or training receives for the purpose of his

maintenance, education or training shall be exempt from tax

in the first-mentioned Contracting State, provided that such

payments are made to him from outside that first-mentioned

Contracting State.



Article 20



Swedish undivided estates



1. Where, under the provisions of this Convention a resident

of Japan is entitled to exemption from, or reduction of,

Swedish tax, similar exemption or reduction shall be applied

to the undivided state of a deceased person insofar as one or

more of the with is a resident of Japan.



2. Swedish tax on the undivided estate of a deceased person

shall, insofar as the income accrues to a beneficiary who is

a resident of Japan, be allowed as a credit against Japanese

tax payable in respect of that income, in accordance with the

the provisions of paragraph 1 of Article 22.



Article 21



Other income



1. Items of income of a resident of a Contracting State,

wherever arising, not dealt with in the foregoing Articles of

This Convention shall be taxable only in that Contracting

State.



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

other than income from immovable property as defined in

paragraph 2 of Article 6, if the recipient of such income,

being a resident of a Contracting State, carries on business

in the other Contracting State through a permanent

establishment situated therein and the right or property in

respect of which the income is paid is effectively connected

with such permanent establishment. In such case, the

the provisions of Article 7 shall apply.



3. Notwithstanding the provisions of the preceding paragraphs

of this Article, items of income of a resident of a

Contracting State not dealt with in the foregoing Articles of

This Convention and arising in the other Contracting State

may be taxed in that other Contracting State.



Article 21A



Limitation of benefits



1. Except as otherwise provided in this Article, a resident

of a Contracting State that derives income described in

paragraph 3 of Article 10 or in Article 11 or 12 from the

other Contracting State shall be entitled to the benefits

granted for a taxable year by the provisions of that

paragraph or those Articles only if such resident is a

qualified person as defined in paragraph 2 and satisfies any

other specified conditions in that paragraph or those

Articles for the obtaining of such benefits.



2. A resident of a Contracting State is a qualified person

for a taxable year only if such resident is either:



(a) an individual;



(b) the Government of that Contracting State, any statutory

body, political subdivision or local authority of that

Contracting State, or the Bank of Japan or the Central Bank

of Sweden (Sveriges Riksbank);



(c) a company, if its principal class of shares is listed or

registered on a recognized stock exchange specified in clause

(i) or (ii) of sub paragraph (c) of paragraph 7 and is

regularly traded on one or more recognized stock exchanges;



(d) a pension fund, provided that, as of the end of the prior

taxable year, more than 50 per cent of the with,

members or participants of that pension fund are individuals

who are residents of either Contracting State;



(e) an organization established under the laws of that

Contracting State and operated exclusively for a religious,

charitable, educational, scientific, artistic, cultural or

public purpose, only if all or part of its income may be

exempt from tax under the domestic law of that Contracting

State; or



(f) a person other than an individual, if residents of either

Contracting State that are qualified persons by reason of

Sub-paragraph (a), (b), (c), (d) or (e) of this paragraph

hold, directly or indirectly, at least 50 per cent of the

voting power or other beneficial interests of that person.



3. Notwithstanding that a company that is a resident of a

Contracting State may not be a qualified person, that company

shall be entitled to the benefits granted by the Commission

of paragraph 3 of Article 10 or of Article 11 or 12 with

respect to an item of income described in that paragraph or

those Articles derived from the other Contracting State if

that company satisfies any other specified conditions in that

paragraph or those Articles for the obtaining of such

benefits and at least 75 per cent of the voting power of that

company is held, directly or indirectly, by seven or fewer

persons who are equivalent with.



4. Where the provisions of sub paragraph (f) of paragraph 2

and paragraph 3 apply:



(a) in respect of taxation by withholding at source, a

the resident of a Contracting State shall be considered to

satisfy the conditions described in that sub-paragraph or

schedule for the taxable year in which the payment of an item of

income is made if such resident satisfies those conditions

during the twelve month period preceding the date of the

payment (or, in the case of dividends, the date on which

entitlement to the dividends is determined);



(b) in all other cases, a resident of a Contracting State

shall be considered to satisfy the conditions described in

that sub-paragraph or paragraph for a taxable year if such

resident satisfies those conditions on at least half the days

of the taxable year.



5. (a) Notwithstanding that a resident of a Contracting State

may not be a qualified person, that the resident shall be

entitled to the benefits granted by the provisions of

paragraph 3 of Article 10 or of Article 11 or 12 with respect

to an item of income described in that paragraph or those

Articles derived from the other Contracting State if:




(i) that the resident is carrying on business in the

the first-mentioned Contracting State (other than the business of

making or managing investments for that resident's own

account, unless the business is banking, insurance or

securities business carried on by a bank, insurance company

or securities dealer);



(ii) the income derived from that other Contracting State is

derived in connection with, or is incidental to, that

business; and



(iii) that the resident satisfies any other specified conditions

in that paragraph or those Articles for the obtaining of such

benefits.



(b) If a resident of a Contracting State derives an item of

income from a business carried on by that resident in the

other Contracting State or derives an item of income arising

in the other Contracting State from a person that has the with

that resident a relationship described in sub-paragraph (a)

or (b) of paragraph 1 of Article 9, the conditions described

in sub-paragraph (a) of this paragraph shall be considered to

be satisfied with respect to such item of income only if the

business carried on in the first-mentioned Contracting State

the is substantial in relation to the business carried on in that

other Contracting State. Whether such business is substantial

for the purposes of this paragraph shall be determined on the

the basis of all the facts and circumstances.



(c) In determining whether a person is carrying on business

in a Contracting State under sub paragraph (a) of this

paragraph, the business conducted by a partnership in which

that person is a partner and the business conducted by

person connected to such person shall be deemed to be

conducted by such person. (A) the person shall be connected to

another if one holds, directly or indirectly, at least 50 per

cent of the beneficial interests in the other (or, in the

case of a company, at least 50 per cent of the voting power

of the company) or a third person holds, directly or

indirectly, at least 50 percent of the beneficial interests

(or, in the case of a company, at least 50 per cent of the

voting power of the company) in each person. In any case, a

person shall be considered to be connected to another if, on

the basis of all the facts and circumstances, one has control

of the other or both are under the control of the same person

or person.



6. A resident of a Contracting State that is neither a

qualified person nor entitled under paragraph 3 or 5 to the

benefits granted by the provisions of paragraph 3 of Article

10 or of Article 11 or 12 with respect to an item of income

described in that paragraph or those Articles shall,

nevertheless, be granted such benefits if the competent

authority of the other Contracting State determines, in

accordance with its domestic law or administrative practice,

that the establishment, acquisition or maintenance of such

the resident and the conduct of its operations are considered as

not having the obtaining of such benefits as one of the

principal purposes.



7. For the purposes of this Article:



(a) the term "shares" shall include depository receipts

thereof;



(b) the term "principal class of shares" means the class or

classes of shares of a company which represent a majority of

the voting power of the company;



(c) the term "recognized stock exchange" means:



(i) any stock exchange established under the terms of the

Financial Instruments and Exchange Law (Law No. 25 of 1948)

of Japan;



(ii) the NASDAQ OMX Stockholm Stock Exchange

(Stockholm Stock Exchange), the Nordic Growth Market, and any other

stock exchange subject to regulation by the Swedish Financial

Supervisory Authority;



(iii) the Irish Stock Exchange and the stock exchanges of

Amsterdam, Brussels, Copenhagen, Dusseldorf, Frankfurt,

Hamburg, Helsinki, Hong Kong, London, Madrid, Milan, New

York, Oslo, Paris, Reykjavik, Riga, Seoul, Shanghai,

Singapore, Sydney, Tallinn, Toronto, Vienna, Vilnius, and

Zurich, and the NASDAQ System; and



(iv) any other stock exchange which the competent authorities

of the Contracting States agree to recognize for the purposes

of this Article;



(d) the term "pension fund" means any person that:



(i) is established under the laws of a Contracting State;



(ii) is operated principally to administer or provide

pension, retirement benefits or other similar remuneration

or to earn income for the benefit of other pension funds;

and



(iii) is exempt from tax in that Contracting State with

respect to income derived from the activities described in

clause (ii); and



(e) the term "equivalent beneficiary" means:



(i) a resident of a state that has a convention for the

avoidance of double taxation and the prevention of fiscal

evasion between that state and the Contracting State from

which the benefits of this Convention are granted such

that:

(aa) that the convention contains provisions for effective

the exchange of information;



(bb) that resident is a qualified person under the limitation

on benefits provisions in that convention or, when there are

no such provisions in that convention, would be a qualified

person when that convention is read as including provisions

corresponding to paragraph 2; and



(cc) with respect to an item of income referred to in

paragraph 3 of Article 10 or in Article 11 or 12 that

resident would be entitled under that convention to a rate of

tax with respect to the particular class of income for which

the benefits are being granted under this Convention that is

at least as low as the rate applicable under this Convention;

or



(ii) a qualified person by reason of sub-paragraph (a), (b),

(c), (d) or (e) of paragraph 2.



Article 21B



Preferential tax regimes



Notwithstanding any other provisions of this Convention,

the where



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

derives its income primarily from other states



(i) from financial or shipping activities, or



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

relationship to, or an entity providing administrative services

or other support to, a group of companies which carry on

business primarily in other states; and



(b) such income would bear a significantly lower tax under

the laws of that Contracting State than income from financial

or shipping activities carried out within that Contracting

State or from being the headquarters or co-ordination centre

in relation to, or an entity providing administrative

services or other support to, a group of companies which

carry on business in that Contracting State, as the case may

pray,



any provisions of this Convention conferring an exemption or

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

company and to the dividends paid by such company.



Article 21 c



Main purpose test



No relief shall be available under this Convention if it was

the main purpose of any person concerned with the creation or

assignment of any right or property in respect of which the

the income is paid or derived to take advantage of this

Convention by means of that creation or assignment.



Article 22



Elimination of double taxation



1. Subject to the provisions of the laws of Japan regarding

the allowance as a credit against Japanese tax of tax payable

in any country other than Japan, where a resident of Japan

from Sweden derives income which may be taxed in Sweden in

accordance with the provisions of this Convention, the amount

of Swedish tax payable in respect of that income shall be

allowed as a credit against the Japanese tax imposed on that

resident. The amount of credit, however, shall not exceed the

amount of the Japanese tax which is appropriate to that

income.



2. (a) Subject to the provisions of sub-paragraph (b) of this

paragraph and of paragraph 6 of Article 10, where a resident

of Sweden derives income which may be taxed in Japan in

accordance with the provisions of this Convention, Sweden

shall allow-subject to the provisions of the laws of Sweden

concerning credit for foreign tax (as they may be amended

from time to time without changing the general principle

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

amount equal to the tax paid in respect of the Japanese such

income.



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

accordance with the provisions of this Convention, shall be

taxable only in Japan, Sweden may, when determining the

graduated rate of Swedish tax, take into account the income

which shall be taxable only in Japan.



Article 23



Non-discrimination



1. Nationals of a Contracting State shall not be subjected in

the other Contracting State to any taxation or any

requirement connected therewith which is other or more

burdensome than the taxation and connected requirements to

which nationals of that other Contracting State in the same

circumstances are or may be subjected. This Commission shall,

Notwithstanding the provisions of Article 1, also apply to

persons who are not residents of one or both of the

Contracting States.



2. The taxation on a permanent establishment which an

Enterprise of a Contracting State has in the other

Contracting State shall not be less favourably levied in that

other Contracting State than the taxation levied on

enterprises of that other Contracting State carrying on the

Sami activities. This provision shall not be construed as

obliging a Contracting State to grant to residents of the

other Contracting State any personal allowances, reliefs and

reductions for taxation purposes on account of civil status

or family responsibilities which it grants to its own

residents.



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

paragraph 6 of Article 11, or paragraph 4 of Article 12 apply,

interest, royalties and other disbursements paid by an

Enterprise of a Contracting State to a resident of the other

Contracting State shall, for the purpose of determining the


the taxable profits of such enterprise, be deductible under the

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

the first-mentioned Contracting State.



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

is wholly or partly owned or controlled, directly or

indirectly, by one or more residents of the other Contracting

State, shall not be subjected in the first-mentioned

Contracting State to any taxation or any requirement

connected therewith which is other or more burdensome than

the taxation and connected requirements to which other

similar enterprises of the first-mentioned Contracting State

are or may be subjected.



5. The provisions of this Article shall, notwithstanding the

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

Description.



Article 24



Mutual agreement procedure



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

of the Contracting States result or will result for him in

taxation not in accordance with the provisions of this

Convention, he may, irrespective of the remedies provided by

the domestic laws of those Contracting States, present his

case to the competent authority of the Contracting State of

which he is a resident or, if his case comes under paragraph

1 of Article 23, to that of the Contracting State of which he

is a national. The case must be presented within three years

from the first notification of the action resulting in

taxation not in accordance with the provisions of this

Convention.



2. The competent authority shall endeavour, if the objection

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

arrive at a satisfactory solution, to resolve that case by

mutual agreement with the competent authority of the other

Contracting State, with a view to the avoidance of taxation

not in accordance with the provisions of this Convention. Any

agreement reached shall be implemented notwithstanding any

time limits in the domestic laws of the Contracting States.



3. The competent authorities of the Contracting States shall

endeavour to resolve by mutual agreement any difficulties or

doubts arising as to the interpretation or application of

This Convention. They may also consult together for the

Elimination of double taxation in cases not provided for in

This Convention.



4. The competent authorities of the Contracting States may

communicate with each other directly for the purpose of

reaching an agreement in the sense of the preceding

paragraphs of this Article.



5. Where,



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

competent authority of a Contracting State on the basis that

the actions of one or both of the Contracting States have

resulted for that person in taxation not in accordance with

the provisions of this Convention, and



(b) the competent authorities are unable to reach an

agreement to resolve that case pursuant to paragraph 2 within

three years from the presentation of the case to the

competent authority of the other Contracting State,



any unresolved issues arising from the case shall be

submitted to arbitration if the person so requests. These

unresolved issues shall not, however, be submitted to

arbitration if a decision on these issues has already been

rendered by a court or administrative tribunal of either

Contracting State. Unless a person directly affected by the

case does not accept the mutual agreement that implements the

arbitration decision, that decision shall be binding on both

Contracting States and shall be implemented notwithstanding

any time limits in the domestic laws of these Contracting

States. The competent authorities of the Contracting States

shall by mutual agreement settle the mode of application of

This paragraph.



6. For the purposes of applying the provisions of paragraph

5:



(a) The competent authorities shall by mutual agreement

establish a procedure in order to ensure that an arbitration

the decision will be implemented within two years from a request

for arbitration as referred to in paragraph 5 unless actions

or inaction of a person directly affected by the case

presented pursuant to that paragraph preclude the resolution of

the case or unless the competent authorities and that person

agree otherwise.



(b) An arbitration panel shall be established in accordance

with the following rules:



(i) An arbitration panel shall consist of three arbitrators

with expertise or experience in international tax matters.



(ii) Each competent authority shall appoint one arbitrator

who may be its national. The two arbitrators appointed by the

competent authorities shall appoint the third arbitrator who

serves as the chair of the arbitration panel in accordance

with the procedures agreed by the competent authorities.



(iii) All arbitrators shall not be employees of the tax

authorities of the Contracting States, nor have had dealt

with the case presented pursuant to paragraph 1 in any

capacity. Unless otherwise agreed by the competent

authorities of the Contracting States, the third arbitrator

shall not be a national of either Contracting State.



(iv) The competent authorities shall ensure that all

arbitrators and their staff agree, in statements sent to each

competent authority, prior to their acting in an arbitration

proceeding, to abide by and be subject to the same

confidentiality and non-disclosure of the bond described in

paragraph 2 of Article 25 and under the applicable domestic

the laws of the Contracting States.



(v) Each competent authority shall bear the costs of its

appointed arbitrator and its own expenses. The costs of the

Chair of an arbitration panel and other expenses associated

with the conduct of the proceedings shall be borne by the

competent authorities in equal shares.



(c) The competent authorities shall provide the information

necessary for the arbitration decision to all arbitrators and

their staff without undue delay.



(d) An arbitration decision shall be treated as follows:



(i) An arbitration decision has no formal precedential

value.



(ii) An arbitration decision shall be final, unless that

the decision is found to be unenforceable by the courts of one of

the Contracting States due to a violation of paragraph 5, of

This paragraph or of any procedural rule determined in

accordance with sub-paragraph (a) of this paragraph that may

reasonably have affected the decision. If the decision is

found to be unenforceable due to the violation, the decision

shall be considered not to have been made.



(e) Where, at any time after a request for arbitration has

been made and before the arbitration panel has delivered a

decision to the competent authorities and the person who made

the request for arbitration, the competent authorities have

solved all the unresolved issues submitted to the

arbitration, the case shall be considered as solved pursuant

to paragraph 2 and no arbitration decision shall be

provided.



7. (a) The provisions of paragraphs 5 and 6 shall not apply

to cases falling within paragraph 3 of Article 4 or to cases

concerning the attribution of capital to a permanent

Re-establishment under Article 7.



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

shall not be submitted to arbitration if the competent

authorities of both Contracting States have agreed that the

case is not suitable for resolution through arbitration.



Article 25



Exchange of information



1. The competent authorities of the Contracting States shall

Exchange such information as is foreseeably relevant for

carrying out the provisions of this Convention or to the

Administration or enforcement of the domestic laws concerning

taxes of every kind and description imposed on behalf of the

Contracting States, or of their political subdivisions or

local authorities, insofar as the taxation thereunder is not

contrary to this Convention. The exchange of information is

not restricted by Articles 1 and 2.



2. Any information received under paragraph 1 by a

Contracting State shall be treated as secret in the same

manner as information obtained under the domestic laws of

that Contracting State and shall be disclosed only to persons

or authorities (including courts and administrative bodies)

concerned with the assessment or collection of, the

enforcement or prosecution in respect of, the determination

of appeals in relation to the taxes referred to in paragraph

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

shall use the information only for such purposes. They may

disclose the information in public court proceedings or in

judicial decisions. Notwithstanding the foregoing,

information received by a Contracting State may be used for

other purposes when such information may be used for such

other purposes under the laws of both Contracting States and

the competent authority of the Contracting State supplying

the information authorizes such use.



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

construed so as to impose on a Contracting State the

bond:



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

laws and administrative practice of that or of the other

Contracting State;



(b) to supply information which is not obtainable under the

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

of the other Contracting State;



(c) to supply information which would disclose any trade,

business, industrial, commercial or professional secret or

trade process, or information, the disclosure of which would

be contrary to public policy (ordre public);



(d) to obtain or provide information that would reveal

confidential communications between a client and an attorney,

the solicitor or other admitted legal representative where such

communications are:



(i) produced for the purposes of seeking or providing legal

advice; or



(ii) produced for the purposes of use in existing or


contemplated legal proceedings.



4. If information is requested by a Contracting State in

accordance with this Article, the other Contracting State

shall use its information gathering measures to obtain the

requested information, even though that other Contracting

State may not need such information for its own tax purposes.

The obligation contained in the preceding sentence is subject

to the limitations of paragraph 3 but in no case shall such

limitations be construed to permit a Contracting State to

decline to supply information solely because it has no

domestic interest in such information.



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

construed to permit a Contracting State to decline to supply

information solely because the information is held by a bank,

other financial institution, nominee or person acting in an

Agency or a fiduciary capacity or because it relates to

ownership interests in a person.



Article 25A



Assistance in recovery



1. The Contracting States shall lend assistance to each other

in the collection of revenue claims. This assistance is not

restricted by Articles 1 and 2.



2. The term ' revenue claim ' as used in this Article means an

amount owed in respect of the following taxes, insofar as the

taxation thereunder is not contrary to this Convention or any

other instrument to which the Contracting States are parties,

as well as interest, administrative penalties, surcharges and

costs of collection or conservancy related to such amount:



(a) in the case of Japan:



(i) the income tax;



(ii) the corporation tax;



(iii) the special income tax for reconstruction;



(iv) the special corporation tax for reconstruction;



(v) the consumption tax;



(vi) the inheritance tax; and



(vii) the gift tax;



(b) in the case of Sweden:



(i) the national income tax;



(ii) the withholding tax on dividends;



(iii) the income tax on non-residents;



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



(v) the municipal income tax;



(vi) the value added tax;



(vii) the real estate tax;



(viii) the net wealth tax;



(ix) the inheritance tax; and



(x) the gift tax;



(c) any identical or substantially similar taxes that are

imposed after the date of signature of the Protocol signed at

Stockholm on 5 December 2013 amending this Convention as

amended by the Protocol signed at Stockholm on 19 February

1999 in addition to, or in place of, the taxes covered by

sub-paragraphs (a) and (b).



The competent authorities of the Contracting States shall

notify each other of any significant changes that have been

made in their taxation laws.



3. When a revenue claim of a Contracting State is enforceable

under the laws of that Contracting State and is owed by a

person who, at that time, cannot, under the laws of that

Contracting State, prevent its collection, that revenue claim

shall, at the request of the competent authority of that

Contracting State, be accepted for purposes of collection by

the competent authority of the other Contracting State. That

revenue claim shall be collected by that other Contracting

State in accordance with the provisions of its laws

applicable to the enforcement and collection of its own taxes

as if the revenue claim were a revenue claim of that other

Contracting State that met the conditions allowing that other

Contracting State to make a request under this paragraph.



4. When a revenue claim of a Contracting State is a claim in

respect of which that Contracting State may, under its law,

take measures of conservancy with a view to ensure its

collection, that revenue claim shall, at the request of the

competent authority of that Contracting State, be accepted

for purposes of taking measures of conservancy by the

competent authority of the other Contracting State. That

other Contracting State shall take measures of conservancy in

respect of that revenue claim in accordance with the

the provisions of its laws as if the revenue claim were a revenue

claim of that other Contracting State even if, at the time

When such measures are applied, the revenue claim is not

enforceable in the first-mentioned Contracting State or is

owed by a person who has a right to prevent its collection.



5. Notwithstanding the provisions of paragraphs 3 and 4, a

revenue claim accepted by a Contracting State for purposes of

paragraph 3 or 4 shall not, in that Contracting State, ask

subject to the time limits or accorded any priority

applicable to a revenue claim under the laws of that

Contracting State by reason of its nature as such. In

addition, a revenue claim accepted by a Contracting State for

the purposes of paragraph 3 or 4 shall not, in that

Contracting State, have any priority applicable to that

revenue claim under the laws of the other Contracting

State.

6. Notwithstanding the provisions of paragraph 5,

acts carried out by a Contracting State in the collection of

a revenue claim accepted by that Contracting State for

purposes of paragraph 3 or 4, which, if they were carried out

by the other Contracting State, would have the effect of

suspending, prolonging or interrupting the time limits

applicable to the revenue claim according to the laws of that

other Contracting State, shall have such effect during the

the laws of that other Contracting State. The first-mentioned

Contracting State shall inform the other Contracting State

about such acts.



7. Proceedings with respect to the existence, validity or the

the amount of a revenue claim of a Contracting State shall not be

brought before the courts or administrative bodies of the

other Contracting State.



8. Where, at any time after a request has been made by a

Contracting State under paragraph 3 or 4 and before the other

Contracting State has collected and remitted the relevant

revenue claim to the first-mentioned Contracting State, the

the relevant revenue claim ceases to be



(a) in the case of a request under paragraph 3, (a) the revenue

claim of the first-mentioned Contracting State that is

enforceable under the laws of that Contracting State and is

owed by a person who, at that time, cannot, under the laws of

that Contracting State, prevent its collection, or



(b) in the case of a request under paragraph 4, a revenue

claim of the first-mentioned Contracting State in respect of

which that Contracting State may, under its law, take

measures of conservancy with a view to ensure its

collection

the competent authority of the first-mentioned

Contracting State shall promptly notify the competent

authority of the other Contracting State of that fact and, at

the option of the other Contracting State, the

the first-mentioned Contracting State shall either suspend or

withdraw its request.



9. In no case shall the provisions of this Article be

construed so as to impose on a Contracting State the

bond:



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

laws and administrative practice of that or of the other

Contracting State;



(b) to carry out measures which would be contrary to public

policy (public policy);



(c) to provide assistance if the other Contracting State has

not pursued all reasonable measures of collection or

Conservancy, as the case may be, available under its laws or

administrative practice;



(d) to provide assistance in those cases where the

administrative burden for that Contracting State is clearly

disproportionate to the benefit to be derived by the other

Contracting State.



10. Before assistance is smooth under the provisions of this

Article, the competent authorities of both Contracting States

shall agree upon the mode of application of this Article,

including an agreement to ensure levels of status

assistance to each of the Contracting States. In particular,

the competent authorities of both Contracting States shall

agree on a limit to the number of applications for assistance

that a Contracting State may make in a particular year and (a)

minimum monetary threshold for a revenue claim for which

assistance is sought.



Article 26



Diplomatic agents and consular officers



Nothing in this Convention shall affect the fiscal privileges

of diplomatic agents or consular officers under the general

rules of international law or under the provisions of special

agreements.



Article 27



Entry into force



1. This Convention shall be ratified and the instruments of

ratification shall be exchanged at Tokyo as soon as

possible.



2. This Convention shall enter into force on the thirtieth

day after the date of the exchange of instruments of

ratification and shall have effect:



(a) in Japan:



as regards income for any taxable year beginning on or after

the first day of January of the calendar year next following

that in which this Convention enters into force; and



(b) in Sweden:



as regards the income derived on or after the first day of

January of the calendar year next following that in which

This Convention enters into force.



3. The Convention between Japan and Australia for the Avoidance

of Double Taxation and the Prevention of Fiscal Evasion with

respect to Taxes on Income signed at Tokyo on December 12,

in 1956, modified and supplemented by the Protocol signed at

Tokyo on April 15, 1964, shall terminate and cease to have

effect in respect of income to which this Convention applies

under the provisions of paragraph 2.



Article 28



Termination



This Convention shall continue in effect indefinitely but

either Contracting State may, on or before the thirtieth day

of June of any calendar year beginning after the expiration

of a period of five years from the date of its entry into

force, give to the other Contracting State, through the

diplomatic channel, written notice of termination and, in

such event, this Convention shall cease to have effect:



(a) in Japan:



as regards income for any taxable year beginning on or after


the first day of January of the calendar year next following

that in which the notice of termination is given; and



(b) in Sweden:



as regards the income derived on or after the first day of

January of the calendar year next following that in which the

notice of termination is given.



In WITNESS WHEREOF, the undersigned, duly authorized thereto

by their respective Governments, have signed this

Convention.



DONE in Duplicate at Stockholm on 21 January 1983 in the

English language.



For the Government of Sweden:



Lennart Bodström



For the Government of Japan:



Wataru Owada



(Translation)



Agreement between Sweden and Japan to avoid

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

taxes on income



The Swedish Government and the Government of Japan,



Desiring to conclude a new agreement to avoid

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

taxes on income,



have agreed as follows:



Article 1



Persons to whom the agreement applies



This agreement shall apply to persons who are domiciled in a

Contracting State or in both Contracting States.



Article 2



Taxes covered by the agreement



1. The taxes covered by this agreement are:



a) in Japan:



1) the income tax;



2) corporate income tax;



3) the special reconstruction tax;



4) the special reconstruction tax for companies; and



5) local taxes on residents



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



b) in Sweden:



1) state income tax;



2) withholding tax;



3) the Special income tax for non-residents;



4) the Special income tax for non-residents

artists, etc.; and



5) the municipal income tax



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



2. This agreement shall also apply to taxes by the same, or in the

mainly similar kind, whether they are governmental or

local – that after the signing of this agreement accrue at

addition to or in place of the taxes referred to in paragraph 1.

The competent authorities of the Contracting States shall

notify each other of substantial changes that were made to the respective

tax legislation within a reasonable period of time after such changes.



Article 3



General definitions



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

the following expression, the following meaning:



a) "Japan" is referring to, when used in the geographical sense,

Japan's territory, including its territorial waters,

in which the laws relating to Japanese tax are in force, and

all area outside its territorial waters, including

the seabed and its surface, over which Japan has

jurisdiction in accordance with the General rules of international law and in the

which the laws relating to Japanese tax are in force;



b) "Sweden" refers to the Kingdom of Sweden and the includes

each outside Sweden's territorial waters located area, within

which Sweden in accordance with international law in General

rules and according to the Swedish law may exercise their rights with

respect to the exploration and exploitation of the

the natural resources of the seabed or in its documentation;



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

the State "refers to Japan or Sweden, depending on

context;



d) "tax" means the Japanese tax or Swedish tax depending on

context;



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

Association;



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

taxes are treated as entity;



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

other Contracting State "refers to the business activities of

resident of a Contracting State, and

business carried on by a resident of the other

Contracting State;



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

either Contracting State and legal person incorporated

or organized under the law of either

Contracting State and association – which is not

legal person, through tax policies in either

Contracting State shall be treated as a legal entity –

which incorporated or organized under the laws of

This Contracting State;



in) "international traffic" refers to transport by ship or

aircraft used by enterprises of a Contracting State

except when the ship or aircraft are used exclusively between

places in the other Contracting State;



j) "competent authority" refers to:



1) in Japan, the Minister of finance or his authorised

agents;



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

or authority to whom be entrusted to be competent

authority for the purposes of this agreement;



k) "company" refers to the pursuit of any kind of movement;

and



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

independent operations.



2. Where a Contracting State applies this agreement is considered,

unless the context gives rise to different, every expression

not defined in the agreement, have the same meaning as the expression

According to the Contracting State in question if the

such taxes to which this agreement is implemented.



Article 4



Resident



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

resident in one Contracting State "person under

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

domicile, residence, place of head office, place of

management or other similar circumstances and

also includes that State, its bodies

or institutions, political subdivisions or local

authorities, and such a pension fund referred to in article

21A item 7 (d)). This expression, however, does not include

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

from sources in that State.



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

a resident of both Contracting States, is determined his residence

in the following ways:



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

residence permanently at his disposal. If he

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

only of the State with which his personal and economic

relations are strongest (Centre of life interests);



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

their living interests or if he is not in any State

has a permanent home available to him;

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

vistas;



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

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

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



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

nationals of any of them, the competent authorities of the

Contracting States may settle the question by mutual

agreement.



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

an individual is a resident of both Contracting States, the

the competent authorities of the Contracting States,

mutual agreement, seek to determine the Contracting

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

This agreement. In the absence of such agreement,

the person in question will not be entitled to any

tax relief or an exemption from tax under this

agreements.



Article 5



Permanent establishment



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

establishment means a fixed place of business,

from which a business wholly or partly

is conducted.



2. The term "permanent establishment" includes especially:



a) place for business management;



b) branch;



c) Office;



d) facility;



e) workshop; and



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

for the extraction of natural resources.



3. Place for construction, landscaping or

installation activities constitutes a permanent establishment only if

the operation lasts more than twelve months.



4. Notwithstanding the preceding provisions of this article

considered the expression "permanent establishment" shall not include:



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

exhibition or disclosure of company-owned goods;



(b) holding of a company belonging) inventories

exclusively for storage, exhibition, or disclosure;



(c) holding of a company belonging) inventories

exclusively for working or processing by other

corporate merchandise;



d) holding of fixed place of business

exclusively for the purchase of goods or obtaining

information for the enterprise;



e) holding of fixed place of business

exclusively for the enterprise carrying on other activities of the

preparatory or auxiliary nature; and



f) holding of fixed place of business

exclusively for combining activities listed in

paragraphs a) – (e)), provided that all the activities

carried out from the permanent location of the

business as a result of this combination is the

preparatory or auxiliary character.



5. If a person, who is not such independent representative on

the provisions of paragraph 6 apply, works for a

companies and in one Contracting State has, and where

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

name, this company – notwithstanding the provisions of

paragraphs 1 and 2 to have a permanent establishment in this

Contracting 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

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


fixed place of business, would not make

This fixed place of business to the firm

establishment, in accordance with the provisions of that paragraph.



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

State only on the basis that the company conducts

business in that Contracting State through the Agency

by brokers, Commissioner, or other independent agent,

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

a company resident in the other Contracting State or in a

companies doing business in this second

Contracting State (either from a permanent establishment or on

otherwise), does not in and of itself to either company

constitute a permanent establishment of the other.



Article 6



Income from immovable property



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

acquires the immovable property situated in the other Contracting

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



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

under the laws of the Contracting State in which the

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

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

Agriculture and forestry, rights to which the provisions of

private law on immovable property apply, buildings,

tenancies of immovable property and rights to changing

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

use mineral occurrence, source or another natural resource.

Ships and aircraft is not considered to be real property.



3. the provisions of paragraph 1 shall apply to income

acquired by immediately use, through rental or

other uses of real property.



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

income from immovable property belonging to the company.



Article 7



Income from operating



1. the Income of an enterprise of a Contracting State

acquire, be taxable only in that Contracting State,

unless the enterprise carries on business in the other

Contracting State through permanent establishment situated there. If

the company carries on business recently, may

the company's income is taxed in the other Contracting

the State, but only so much of them as is attributable to the

the permanent establishment.



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

other Contracting State from which permanent

establishment, unless the provisions of paragraph 3

causing the other, in either Contracting State to the

permanent establishment the income that it can be assumed that

establishment would have acquired if it were a standalone

company, which operated out of the same or a similar kind

under the same or similar conditions and independently completed

business with the undertaking to which the establishment belongs.



3. In determining permanent establishment income permitted

deduction for expenses incurred for the permanent establishment,

hereunder included expenses for the company's management and

General management, whether the expenditure incurred in the

Contracting State in which the permanent establishment is situated

or elsewhere.



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

the reason to purchase goods through the permanent establishment

merchandise for the enterprise.



5. for the purposes of the provisions of the preceding paragraphs of the

This article determines the income as is attributable to that permanent

establishment by the same procedure from year to year, unless

good and sufficient reasons causing the other.



6. Included in income by operating income processed

especially in other articles of this agreement, concerned

the provisions of these articles of the rules of

the present article.



Article 8



Sea and air transport



1. income as a company of a Contracting State acquires

through the use of ships or aircraft in international

traffic shall be taxable only in that Contracting State.



2. with regard to enterprises of a Contracting State who carries on

international traffic through the use of the ship or

aircraft terms, that such a company, if it is a

company, is exempted from corporate income tax in Japan and, if

It is a Japanese company, is excluded from each Swedish

tax business tax similar in Japan which henceforth can

be charged in Sweden.



3. the provisions of the preceding paragraphs of this article

also apply to income that is acquired through participation in a

a pool, a joint business or an international

the operating organization.



Article 9



Companies with associated enterprises



1. In cases where the



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

participate in the management or control of an undertaking within the

other Contracting State or own part in this business

capital, or



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

or the control of a company of a Contracting

State as an enterprise of the other Contracting State, or

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



If between businesses in terms of trade relations or

financial relations agreed upon or prescribed conditions,

which differ from those which would have been agreed between the

independent companies, receives all the income, that without such

the conditions would have been one company but on

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

included in this corporate income and are taxed in

accordingly.



2. In the case of a Contracting State, in accordance with

the provisions of paragraph 1, in the income of a corporation in this

Contracting State include – and accordingly

taxes – income, for which a company in the other

Contracting State subject to tax in the other Contracting

State and provided that the competent authorities of the

Contracting States, after deliberation, agree

It thus included the income or part of it is such

that would have been the company in the first

Contracting State on the terms agreed between

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

independent enterprises, then that other Contracting

State conduct proper adjustment of the amount of the tax

incurred for income there. In compliance with such other adjustment

provisions of this agreement.



Article 10



Dividend



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

to a resident of the other Contracting State,

be taxed in that other Contracting State.



2. Dividends may be taxed in the

Contracting State of which the company paying the dividends has

the resident, in accordance with the laws of that Contracting State,

But if the beneficial owner of the dividends is a resident of the

other Contracting State may not exceed 10

per cent of the gross amount of the dividends.



3. Notwithstanding the provisions of paragraph 2, dividends not

be taxed in the Contracting State of which the company paying the

the dividend is a resident, if the beneficial owner of the dividend

is resident in the other Contracting State and is a

companies (with the exception of trading companies) that for a period of

six months immediately before the date on which it will be determined who is

entitled to dividends is held, directly or

indirectly, at least 10% of the company

number of votes. The expression "partnership" refers to when applying

of this paragraph is not a person who is treated for tax purposes

as a legal entity of a Contracting State and has

resident in that Contracting State.



4. the provisions of paragraphs 2 and 3 shall not affect the company's

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



5. the provisions of paragraph 3 shall not apply to dividends

paid by a company which is entitled to a deduction for the left

dividends on taxation in the Contracting State in which the

the company paying the dividends is a resident.



6. Notwithstanding the provisions of paragraph 1 are dividends from

companies established in Japan to companies established in Sweden

exempt from Swedish tax if the dividend would have been

exempt under Swedish law if both companies had been

Swedish companies. However, that applies only if the profit of the

the dividend will be paid has been subject to normal

corporate tax in Japan or an income tax comparable thereby.



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

of shares or other rights, not being debt, with

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

companies, which, according to the tax laws of the Contracting

State of which the company making the distribution is a resident for tax purposes

be treated in the same way as income from shares.



8. the provisions of paragraphs 1, 2, 3, 4 and 5 shall apply

No, if the beneficial owner of the dividends is a resident of a

Contracting State, carries on business in the other

Contracting State, where the company paying the dividends

residence, from where the permanent establishment situated, as well as the

share on account of which the dividend is paid owns real

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

the provisions of article 7.



9. If the company resident in one Contracting State acquires

income from the other Contracting State, that other

Contracting State does not tax dividends paid by the company

pay, except to the extent that the dividend paid to the person with

a resident of the other Contracting State or to the extent that the

share on account of which the dividend is paid owns real


connected with a permanent establishment in the other Contracting

State, and neither tax the company's undistributed profits,

Although the dividend or the undistributed profit completely

or partly consists of income arising in that other

Contracting State.



Article 11



Interest rate



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

a resident of the other Contracting State has the right

to, be taxable only in that other Contracting State.



2. Notwithstanding the provisions of paragraph 1, the rate

derived from a Contracting State may also be taxed in that

State, under the law of that Contracting State, if

the size is dependent on income, sales,

revenue, profits or other cash flow of the debtor or

related person, the change in value of property

belonging to the debtor or related person or by

stock dividends, the payout to partner or similar

payment from the debtor or related person,

or by any other similar interest. If the person who has the right to

the interest rate is a resident of the other Contracting State,

the tax, however, not exceed 10% of the interest

gross amount.



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

each kind of claim secured by either the

mortgage on immovable property or not, and whether it involves

the right to the profits or not. The expression refers to

in particular, income from securities issued by State and

income from bonds or debentures, including

premiums and benefits pertaining to such

securities, bonds or debentures; The expression refers to

also any other income which under the laws of the

Contracting State where the income derived by the

taxation of income of lent

money. Penalty for late payment is not considered as

interest for the purposes of this article. Income referred to in

Article 10 shall not be regarded as interest for the purpose of

This agreement.



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

who is entitled to the interest is resident in a Contracting State

and carries on business in the other Contracting State from

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

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

with the permanent establishment. In such a case be applied

the provisions of article 7.



5. interest shall be deemed to arise from a Contracting State if

the payer is that Contracting State itself, a local

authority or a resident of that Contracting

State the person. However, if paying the interest, whether

He is domiciled in a Contracting State or not, in a

Contracting State has a permanent establishment in connection with which the

debt is incurred on which the interest is paid, and the interest rate charged

the permanent establishment are considered interest stem from the

Contracting State in which the permanent establishment is situated.



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

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

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

the interest is paid, exceeds the amount which would be

agreed between the payer and the beneficial owner of the interest

If such links do not exist, the

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

such cases are taxable surplus amount referred to in

the law of each Contracting State with

observance of the other provisions of this agreement.



Article 12



Royalty



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

a resident of the other Contracting State has the right

to, be taxable only in that other Contracting State.



2. The term "royalties" in this article each

kind of payment that is received as compensation for the use

by or for the right to use copyright to literary,

artistic or scientific work, including

cinema films and films or tapes for radio or

television broadcasting, any patent, trade mark, design or

model, plan, secret formula or secret

manufacturing process, or for information concerning findings of

industrial, commercial or scientific experience.



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

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

carries on business in the other Contracting State, from

the royalties derived from the permanent establishment situated there,

and the right or property in respect of which the royalty

paid owns truly connected with the permanent establishment. In

in such cases the provisions of article 7.



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

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

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

the right or the enlightenment for which royalties are payable,

exceeds the amount which would have been agreed between

the payer and the beneficial owner of royalties if such

relations do not exist, the provisions of this

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

excess amounts in accordance with the legislation of each

Contracting State in compliance with the other provisions

in this agreement.



Article 13



Capital gain



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

acquires from the alienation of such immovable property

referred to in article 6 and situated in the other

Contracting State, may be taxed in that other

Contracting State.



2. Gains from the alienation of property, other than the fixed

property forming part of the business assets of the firm

establishment which an enterprise of a Contracting State has

in the other Contracting State, may be taxed in that

other Contracting State. The same applies to profit due to

the transfer of such a permanent establishment (alone or

together with the whole enterprise).



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

acquires from the alienation of ships or aircraft

used in international traffic and other property than fast

property that is attributable to the use of such ships

or aircraft, shall be taxable only in that Contracting

State.



Article 14 (repealed)



Article 15



Single service



1. the provisions of articles 16 and 18, causing the

other, taxable wages and other similar remuneration, with

except for retirement, as a resident of a

Contracting State receives on account of employment, only in

This Contracting State, unless the work is carried out in the

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

Contracting State, the remuneration received for work

be 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 Contracting State, if:



(a)) the recipient resides in the other Contracting State under

time period or periods totalling not more than

183 days during a 12-month period commencing or ending

during the tax year in question; and



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

in the other Contracting State, or on his behalf;

as well as the



c) compensation does not affect the permanent establishment

the employer has in the other Contracting State.



3. Notwithstanding the provisions of the preceding paragraphs of this

Article receives compensation for work performed on board ship

or aircraft used in international transport of

enterprises of a Contracting State, be taxed in that

Contracting State.



Article 16



Directors ' fees



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

resident in one Contracting State receives as a Member

in a Board or other similar bodies in companies established in

the other Contracting State, may be taxed in that other

Contracting State.



Article 17



Artists and athletes



1. Notwithstanding the provisions of articles 7 and 15,

income, as a resident of a Contracting State

acquire through their personal activities in the other

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

or movie actor, radio or television artist, or

musician or athlete, be taxed in that other

Contracting State.



However, such income is exempt from tax in this

other Contracting State if the natural person resident in the

first-mentioned Contracting State exercising such activities

According to a special programme for cultural exchange that

the Governments of the two Contracting States have come

agree on.



2. In cases where the income through personal activities, artist

or athlete exercised in that capacity, not become the property of

the artist or sportsman himself but to another person,

This income, notwithstanding the provisions of articles 7

and 15, be taxed in the Contracting State in which the artist

or athlete exercising activities.



However, such income is exempt from tax in this

Contracting State on income acquired by business

as a natural person resident in the other Contracting

the State exerts under a special program for cultural

Exchange that the Governments of the two Contracting States have

agreed and the income goes to the other person

is a resident of that other Contracting State.



Article 18



Public service



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

a Contracting State or of its local authorities to


natural person because of public artwork in this

Contracting State or of its local authorities ' service,

be taxable only in that Contracting State.



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

Contracting State if the work is done in this second

Contracting State and the person concerned is resident in this

other Contracting State:



1) is a national of that other Contracting State; or



2) resident in that other Contracting State

exclusively to carry out the work.



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

contribution submitted by, a Contracting State or its local

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

in that Contracting State or of its local authorities

service, shall be taxable only in that Contracting State.



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

Contracting State of the habitual residence of the person concerned and is

nationals of that other Contracting State.



3. the provisions of articles 15, 16, 17 and 21 apply to

compensation and pension payable by reason of work

performed in connection with business carried on by a

Contracting State or of its local authorities.



Article 19



Students



A student or business trainee who is, or immediately

before the stay in a Contracting State a resident of the

other Contracting State and who is staying in the former

Contracting State exclusively for teaching or

education, exempt from taxation in the first-mentioned

Contracting State for the amount that he receives for his

living, teaching or training, in

provided that the amount paid to him from source

outside this former Contracting State.



Article 20



Swedish undivided estates



1. In cases where pursuant to the provisions of this agreement, any person with

live in Japan is eligible for exemption from or

a reduction in the rate of Swedish tax, then the corresponding exemption or

reduction granted co-ownership to the extent that one or more

The Inheritors is a resident of Japan.



2. Swedish tax on co-ownership shall, to the extent that the income

apply Inheritors resident in Japan, be offset against

Japanese tax payable on that income in accordance with

the provisions of article 22, paragraph 1.



Article 21



Other income



1. income as a resident of a Contracting State

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

This agreement shall be taxable only in that Contracting State,

regardless of where the income is derived.



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

excluding income from immovable property referred to in article 6

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

Contracting State, carries on business in the other

Contracting State through permanent establishment situated there, and

the right or property in respect of which the income

paid owns truly connected with the permanent establishment. In

in such cases the provisions of article 7.



3. income which are not dealt with in the foregoing articles in

This agreement, as a resident of a Contracting State

acquires and derived from the other Contracting

the State, may, notwithstanding the provisions of the preceding

points in this article, be taxed in that other

Contracting State.



Article 21A



Limitation of benefits



1. Unless otherwise specified in this article so a person with

resident in one Contracting State, which receives such income

referred to in article 10 paragraph 3 or in articles 11 or 12

derived from the other Contracting State, be

entitled to benefits under that legislation a certain

tax year only if the person is a qualified person

According to paragraph 2 and meets the special conditions laid down

for such benefits in those provisions.



2. A resident of a Contracting State is a

the qualified person with respect to a certain year

only if the person is:



a) a natural person;



(b)) a Contracting State, its bodies,

political subdivisions or local authorities, or

Japan's Central Bank, or Riksbank;



c) a company, if its principal class of shares is listed on a

recognised stock exchange referred to in paragraph 7 (c)) 1) or 2) and

regularly traded on one or more recognized stock exchanges;



d) a pension fund, if at the end of the immediately preceding

tax year more than 50 percent of pension fund

beneficiaries, members or participants were individuals

a resident of either Contracting State;



e) an organization formed under the law of a

Contracting State and operated exclusively in religious,

charitable, educational, scientific, artistic,

cultural or public purpose, but only if the entire

or part of its income may be exempt from

taxation according to the laws of the Contracting State;

or



f) a person who is not a natural person, if at least 50

percent of the voting rights or other equity in person

held directly or indirectly by persons resident in

either Contracting State who are qualified persons

According to a), b), c), (d)) or e) of this paragraph.



3. A company resident in a Contracting State shall also

If it is not a qualified person to be entitled to

contractual benefits for such income referred to in article 10

paragraph 3 and articles 11 or 12, and derived from the

other Contracting State, if the company meets the

specific conditions laid down for such benefits in that

and at least 75 percent of the company's voting power

held, directly or indirectly, by seven or fewer people

that meets the conditions to be equivalent

beneficiaries.



4. In the case of paragraph 2 (f)) and paragraph 3 shall be applied:



(a)) in respect of withholding taxes, a resident of a

a Contracting State shall be deemed to comply with the terms of these

provisions the tax year in which the income is paid on

the person concerned satisfies the conditions during the period of 12 months

prior to the payment (or, in the case of a dividend, the

day when it is determined who is entitled to the dividend),



(b)) in respect of other taxes, to a resident of a

a Contracting State shall be deemed to comply with the terms of these

provisions in respect of a taxation year if the person

satisfies the conditions laid down for at least half of the

fiscal year.



5. a) A person who is domiciled in a Contracting State shall

"even if the person is not a qualified person – be

entitled to benefits for income under article 10

paragraph 3, or article 11 and 12 which are derived from the other

Contracting State, if:



1) the person carries on business in that Contracting

the State (with the exception of motion that consists in making

capital investments or to manage investments for

the person's own behalf, unless this movement does not constitute

banking, insurance or securities operations conducted by

a bank, an insurance company or a

securities traders),



2) income derived from the other Contracting State

acquired in connection with, or are subordinate to, movement,

and

3) the person meets the specific conditions for the

obtain such benefits referred to in that paragraph or

articles.



b) If a resident of a Contracting State receives

income from operating as the person carries on in the other

Contracting State or in receipt of income derived from

the other Contracting State and is paid by a person

with whom the first-mentioned person is associated enterprises,

as indicated in article 9, paragraph 1 (a)), or (b)), shall, in

relation to such income, terms of a) of this paragraph

be deemed to be satisfied only if the movement carried out in the

first State is substantial in relation to the

motion carried on in the other Contracting State. At

the purpose of this paragraph, the question of whether a motion is

significant or not, to be determined taking into account all

facts and circumstances.



(c)) in determining if a person carries on business in a

Contracting State for the purposes of a) of this paragraph,

should a movement undertaken by a partnership in which the person

is partner or a movement undertaken by people with whom

the person is affiliated is considered a movement undertaken by the

the person. A person shall be considered to be related to another person

If one of the people is the rightful owner, instantly

or indirectly, by at least 50 percent in the other person

(or, in the case of a corporation, at least 50% of the voting rights

in the company), or, if a third person is the rightful

owner, directly or indirectly, at least 50 percent of each

and one of the persons (or in the case of a corporation, at least 50

percent of the voting rights in the company). A person should always

is considered to be closely related to another if one person, with

taking into account all facts and circumstances,

controls the other, or if both persons are checked

by the same person or persons.



6. A resident of a Contracting State which is not

a qualified person and in accordance with paragraphs 3 or 5

Neither is eligible for benefits for income

set out in article 10 paragraph 3 and articles 11 and 12, shall

Nevertheless, enjoy such benefits if the competent authority of

the other State finds, in accordance with its

legislation and administrative practices, to the establishment,

the acquisition or possession of such a person and pursuit

of its activity does not have as one of its main

purposes to qualify for such benefits.




7. For the purposes of this article:



(a)) refers to the term "shares" also depositary receipts;



(b)) refers to the expression "principal class of shares" or the

class that represents the majority of the voting rights in

the company;



c) refers to the term "recognized stock exchange":



1) each stock exchange established in accordance with the Japanese

Securities and Exchange Act ("Financial Instruments and

Exchange Law ") (Law No 25 of 1948),



2) OMX Nordic Growth Market (NGM) and each

other stock-market under the supervision of

The Swedish financial supervisory authority,



3) the Irish Stock Exchange and the stock exchanges in Amsterdam,

Brussels, Copenhagen, Düsseldorf, Frankfurt, Hamburg,

Helsinki, Hong Kong, London, Madrid, Milan, New York,

Oslo, Paris, Reykjavik, Riga, Seoul, Shanghai, Singapore,

Sydney, Tallinn, Toronto, Vienna, Vilnius and Zurich, as well as

"NASDAQ"-system, and



4) any other stock exchange that the competent authorities of the

Contracting States for the purposes of this article,

agree,



d) refers to the expression "pension fund" means any person who:



1) is established in accordance with the law of a

Contracting State,



2) mainly operates to administer or

provide pensions, pension benefits or other

similar consideration, or to obtain income to

the benefit of other pension funds, and



3) is exempt from tax in the Contracting State of

income from such activities as listed above under 2), and



e) refers to the expression "comparable beneficiaries":



1) a resident of a State which has an agreement to

avoidance of double taxation and the prevention of fiscal evasion with

Contracting State in which the contract benefits under this

agreement is requested and



AA) the agreement contains provisions on

Exchange of information,



BB) the person is a qualified person in accordance with the provisions

the limitation on benefits in the agreement, or where such

provisions do not exist, would have been a qualified

person if the agreement had provisions equivalent to those in the

paragraph 2, and



CC) person in accordance with the agreement would be

entitled, in respect of income referred to in article 10

paragraph 3 or in articles 11 or 12, a tax rate for a

such income that is at least as low as the rate

under this agreement, or



2) a qualified person in accordance with paragraph 2 (a)), b), c),

d) or (e)).



Article 21B



Bargain skatteregimer



Notwithstanding other provisions of this agreement, if



(a)) a company resident in a Contracting State

mainly acquires its income from other States



1) from the finance or shipping activities, or



2) by head office, the coordination centre or a

entity providing administrative or other services

to a group of companies engaged in operating mainly in

other States, and



b) such income is taxed at a significantly lower under

the laws of that Contracting State than income from

financial or shipping activities carried out within this State

or by being the head office, the coordination centre or

a device that provides administrative or other

services to a group of companies that conduct business in this

Contracting State,



to the provisions of this agreement which allow for derogation from the

or reduction of tax is not applied to income

such a company acquires nor on dividend

paid by such a company.



Article 21 c



Examination of the purpose



Relief under this Agreement shall not be obtained if the

main purpose, of any person who has influence over

creation or placement of units or property on

because of which the income is paid or from which the

stems, is to obtain the benefit of this agreement by such

creation or placement.



Article 22



Avoidance of double taxation



1. With regard to the laws of Japan with regard to

the possibility of offsetting against Japanese tax, tax

payable in any country other than Japan, the following applies. If a person

resident in Japan receives income from Sweden that according to

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

Swedish tax paid on this income be offset against the

Japanese tax imposed on that person. Settlement amount

may not, however, exceed the sum of the Japanese tax

that is attributable to such income.



2. a) With regard to b) of this paragraph and article 10 point

6, if a person resident in Sweden receives income that

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

Sweden – having regard to the provisions in Swedish

legislation relating to the deduction of foreign taxes (even in

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

general principle referred to this change) – from the Swedish

tax on income set off an amount equal to the

Japanese tax paid on income.



b) where a resident of Sweden receives income in

accordance with this Agreement shall be taxable only in Japan,

Sweden, in determining the tax rate for the Swedish

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

in Japan.



Article 23



Prohibition of discrimination



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

Contracting State be subject to taxation or

related requirements are of a different kind or more

burdensome than the taxation and related requirements

as a national of that other Contracting State under the same

conditions are or may be subject to. Notwithstanding the

the provisions of article 1 shall apply this provision also

the person who is not domiciled in a Contracting State, or

in both Contracting States.



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

Contracting State has in the other Contracting State,

in that other State shall not be less favourable than

taxation of a company in the other State, that carries

activities of the same kind. This provision is not considered

entail the obligation of a Contracting State to grant to

residents of the other Contracting State such

personal deductions for tax purposes and tax exemption

or reductions because of marital status or

dependants against family allowed resident of

their own State.



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

Article 11, paragraph 6, 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

conditions as payment to a resident of the

first-mentioned Contracting State.



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

partly owned or controlled, directly or indirectly, by a

or more persons resident in the other Contracting

State, not in the first-mentioned Contracting State be

subject to taxation or related requirements

is other or more burdensome than the taxation and

related requirements as other similar companies in the

first-mentioned Contracting State are or may be

subject to.



5. Notwithstanding the provisions of article 2 shall be applied

the provisions of the present article on the treasures of every kind

and nature.



Article 24



The procedure for the mutual agreement



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

Contracting States adopted measures which for him

causes or will result in taxation contrary to

the provisions of this agreement, he may, without

affecting his right to make use of the legal remedies

in those Contracting States ' internal legal order,

submit the matter to the competent authority of the

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

the application of article 23, paragraph 1, of the Contracting State

of which he is a national. The matter should be presented within three years from

the time when the person in question had knowledge of the action

giving rise to taxation contrary to

the provisions of this agreement.



2. If the competent authority finds the complaint justified

but cannot achieve a satisfactory

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

agreement with the competent authority of the other

Contracting State in order to avoid taxation which

contrary to the provisions of this agreement. Agreement

reached shall be implemented notwithstanding any time limits in the

Contracting States ' internal legislation.



3. the competent authorities of the Contracting States shall

by mutual agreement, seek to determine or

doubts arising concerning the interpretation or

the application of this agreement. They can also consult in order

to eliminate double taxation in cases not covered by

This agreement.



4. the competent authorities of the Contracting States may

enter into direct relations with each other in order to meet

agreement in the cases specified in the preceding paragraphs in

This article.



5. In cases where,



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

request to the competent authority of a Contracting

State on the grounds that the actions of one or both

Contracting States to him has brought about taxation in

violation of the provisions of this agreement, and



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

to the competent authority of the other Contracting


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

paragraph 2,



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

matter shall be referred to arbitration. Such unresolved

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

Court in any of the Contracting States have notified

a decision on these issues. The award is binding for

both Contracting States and shall be carried out without barriers

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

unless a person directly affected by the matter not

accept the mutual agreement that implements

the award. The competent authorities of the Contracting

States shall agree on way to apply

This paragraph.



6. for the purposes of applying the provisions of paragraph 5:



(a)), the competent authorities shall, by mutual

Agreement put in place a procedure to ensure that

the arbitration will be conducted within two years of the request for

arbitration under paragraph 5, unless the action or

inaction from a person directly affected by the matter under

that paragraph prevents that the matter is resolved or if not the

competent authorities and the person agree on

other things.



b) an arbitral tribunal shall be established in accordance with the following rules:



1) an arbitral tribunal shall be composed of three arbitrators who have

expertise and experience in matters of international tax.



2) competent authorities shall appoint their arbitrator.

Such arbitrator may be a citizen of The Contracting State.

two arbitrators designated by the competent authorities shall

appoint the third arbitrator who shall be the arbitral

the President, in accordance with the procedure which the competent

authorities agreed.



3) Arbitrators shall not be employees of the Contracting

States ' tax authorities, and must not, in any

form, have dealt with the case that has been presented in

accordance with paragraph 1. The third arbitrator shall not be

nationals of any of the Contracting States, unless the

competent authorities agreed otherwise.



4) the competent authorities shall ensure that all

arbitrators and their staff, before commencing their duties,

to the competent authorities in writing an assurance

on that subject and to comply with the obligations

respect privacy and confidentiality as described in the article

25 paragraph 2 and to the Contracting States

internal legislation.



5) competent authorities shall each bear the cost

of their appointed arbitrator and of its own expenditure. The cost

the Chairman of the arbitral and other expenditure on

the arbitration shall be borne by the competent authorities of

equal parts.



(c)), the competent authorities shall without undue delay submit

the information that is necessary for the award of

arbitrators and their staff.



d) an arbitral award shall be treated as follows:



1) an arbitration decision has no precedential value.



2) An arbitration is binding, unless a court or Tribunal of a

Contracting State determines that the judgment is not enforceable

because it is contrary to paragraph 5, at this point or, if

It may reasonably be expected to affect the outcome, against agreement

If the procedure under (a)) of this paragraph. If the award is assessed

not be executed, it shall be deemed to be notified.



e) If, at any time after a request for

Arbitration has been made and before the Tribunal have

announced an award to the competent authorities and the

person who requested the arbitration proceedings, the competent

authorities have resolved all outstanding issues referred

to arbitration, the case is considered solved in accordance with the

point 2 and an arbitral award shall not be notified.



7. a) the provisions of paragraphs 5 and 6 shall not apply

on matters relating to article 4 paragraph 3 nor on

cases concerning the entry of capital into a fixed

establishment within the meaning of article 7.



b) Notwithstanding the provisions of paragraph 5, a case

not be referred to arbitration if the competent

the authorities of the Contracting States have agreed

that the case should not be determined by

arbitration.



Article 25



Exchange of information



1. the competent authorities of the Contracting States shall

Exchange such information likely to be relevant to the

application of the provisions of this agreement or for

Administration or enforcement of internal law in

question about taxes of every kind and nature levied

for the Contracting States, or of their political

subdivisions or local authorities, on the taxation

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

of information is not restricted by articles 1 and 2.



2. information that a Contracting State received under

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

information obtained in accordance with the internal law

in this State and shall be disclosed only to persons or

authorities (including courts and administrative bodies)

establishing, receives or collects the taxes

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

These taxes or supervising those

activities. Such persons or authorities shall use the

information only for such purposes. They may disclose

the information in public court proceedings or in

Court decisions. Notwithstanding the above,

information which a Contracting State received be used

other purposes when such information may be used for such

other purposes according to the laws of both Contracting

States and the competent authority of the Contracting

State which has provided the information have allowed such

using.



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

for a Contracting State that:



a) take administrative measures derogating from the legislation

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

the other Contracting State;



b) provide information that is not available under

legislation or the usual administrative practice in this

Contracting State or of the other Contracting

the State;

c) supply information which would disclose any commercial,

industrial, commercial or professional secret, or in

trade used the process or information,

the surrender would be contrary to ordre public considerations (

public);



(d)) to obtain or provide information that would

reveal confidential communications between a client and

his lawyer or other legal professional, when such

communication:



1) in order to obtain or provide legal advice;

or



2) in order to be used in ongoing or planned

legal proceedings.



4. Where a Contracting State requests information under this

Article, the other Contracting State shall use the funds

as this State has to obtain the required

the information, even though that other State may not need

information for its own tax purposes.

The obligation in the previous sentence is limited by the provisions

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

Contracting State to refuse to provide information exclusively

because this State has no private interest of such

information.



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

Contracting State to decline to supply information

solely because the information is held by a bank,

other financial institution, agent, representative or

managers or information regarding ownership

in a person.



Article 25A



Assistance with debt collection



1. the Contracting States shall provide each other assistance

for the recovery of tax claims. Assistance limited

not by articles 1 and 2.



2. The expression "tax claim" refers to the case of the application of

This article related to a debt in respect of the following taxes, to the extent

taxation is not contrary to this agreement or any other

contracts which the Contracting States have concluded, plus interest,

administrative fines, surcharges and costs

for recovery or precautionary measures in view of a

such debt:



a) in Japan:



1) the income tax;



2) corporate income tax;



3) the special reconstruction tax;



4) the special reconstruction tax for companies;



5) consumption tax;



6) inheritance tax; and



7) gift tax;



b) in Sweden:



1) state income tax;



2) withholding tax;



3) the Special income tax for non-residents;



4) the Special income tax for non-residents

artists, etc.;



5) the municipal income tax;



6) value added tax;



7) property tax;



8) property tax;



9) inheritance tax; and



10) gift tax.



c) taxes of the same or substantially similar kind after

the signing of the Protocol signed in

Stockholm on 5 december 2013 and which changed this agreement,

as amended by the Protocol signed in Stockholm

on 19 February 1999, charged alongside or instead of

the taxes referred to in subparagraph (a)) and (b)).



The competent authorities of the Contracting States shall

notify each other of substantial changes that have been made in their

tax legislation.



3. When a tax claim of a Contracting State is possible

to execute according to the Contracting State

and the claim is payable by a person who at the time

According to the Contracting State cannot

oppose its recovery, then that asset, after

request of the competent authority of the Contracting


for the recovery state, recognised by the competent authority in

the other Contracting State. This asset should

recovered by the other Contracting State in accordance with

provisions of the legislation of the State of enforcement

and the collection of its own taxes as if the claim were a

tax in that other Contracting State that met

the requirements for such other Contracting State could

make a request under this paragraph.



4. When a tax claim of a Contracting State is a

the claim for which the Contracting State according to its

legislation may take precautionary measures to ensure

recovery, then that asset, after submission of the

competent authority of the Contracting State, recognised

for the taking of precautionary measures by the competent

authority of the other Contracting State. The other

Contracting State shall for this tax asset take

assurance measures in accordance with the provisions of the legislation of that State

legislation as if the claim were an asset in this

other Contracting State, even if, at the time of such

measures are taken, the tax claim is not enforceable in the

first-mentioned Contracting State or to be paid by a

person who can oppose its recovery.



5. Notwithstanding the provisions of paragraphs 3 and 4, a

tax asset, which has been recognized by a Contracting State in

accordance with paragraph 3 or 4, in the Contracting State

not subject to time limits or be given preferential rights that apply

for tax receivables according to the legislation of the

Contracting State. Nor should a tax asset that

has been recognized by a Contracting State in accordance with paragraph 3

or (4) of the Contracting State be given a preferential right as

tax claim under the legislation of the other

Contracting State.



6. Notwithstanding the provisions of paragraph 5, measures

taken by a Contracting State in implementing a

tax asset that has been recognised by the Contracting State in

accordance with paragraph 3 or 4, as if they had been taken by

the other Contracting State and then brought to

the deadline for the tax claim under the other Contracting

State law had been suspended, extended or

canceled, have such an effect as the other Contracting

State legislation. The first-mentioned Contracting State

shall notify the other Contracting State if such

documents.



7. Procedures concerning the existence, validity or

the scope of a tax claim of a Contracting State shall

not be brought before the courts or administrative authorities

in the other Contracting State.



8. If, after a request has been made by a

Contracting State referred to in paragraph 3 or 4, but before the

other Contracting State have pushed into and transferred

tax asset to the first-mentioned Contracting State, the

the tax applies ceases to be



(a)) in case of a request pursuant to paragraph 3, a

tax claim in the first-mentioned Contracting State that is

possible to execute according to the Contracting State

legislation and shall be paid by a person who, at the

the time can't resist its recovery in accordance with

the law of the Contracting State, or



b) in the case of a request referred to in paragraph 4, a

tax claim in the first State for which the

Contracting State under its laws may take

precautionary measures to ensure recovery



the competent authority of the first-mentioned Contracting

State shall without delay inform the competent authority of

the other State this and the former

Contracting State shall, in accordance with the second

Contracting State wishes, either stay the

or withdraw its request.



9. the provisions of this article do not entail the obligation of

a Contracting State that:



a) take administrative measures derogating from the legislation

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

the other Contracting State;



b) take action that would be contrary to the General account

(public policy);



c) provide assistance if the other Contracting State not

has taken all reasonable measures for the recovery or

assurance measures at its disposal in accordance with its

legislation or administrative practice;



d) provide assistance in cases where the administrative burden

for this Contracting State clearly does not

proportion to the benefit which stands to win for the second

Contracting State.



10. Before the assistance provided pursuant to the provisions of this

Article, the competent authorities of the Contracting

States reach agreement on the way to apply this

Article, which ensure a comparable scope of

assistance to each of the Contracting States. In

particular, the competent authorities of the Contracting

States agree on a limit on the number of

requests for assistance which a Contracting State

can make in a given year as well as a minimum threshold for

a deferred tax asset in respect of which the assistance is requested.



Article 26



Diplomatic representatives and consular officials



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

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

provisions of specific agreements apply

diplomatic representatives or consular officials.



Article 27



Date of entry into force



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

should be exchanged in Tokyo as soon as possible.



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

the exchange of the ratification documents were made and shall

applied:



a) in Japan:



with respect to the income attributable to fiscal years that begin

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

enters into force, or later; and



b) in Sweden:



with regard to income acquired on 1 January of the calendar year

immediately following the this agreement enters into force or later.



3. the agreement between Japan and Sweden for the avoidance of

double taxation and the prevention of fiscal evasion with respect to

taxes on income, signed at Tokyo on december 12

in 1956, and that was, and was supplemented by the Protocol

signed in Tokyo on april 15, 1964, shall be repealed

and no longer apply in respect of income on which

This agreement becomes applicable in accordance with the provisions of paragraph

2.



Article 28



Termination



This agreement will remain in force indefinitely but each of

the Contracting States possess to – 30 June

during a calendar year beginning after the expiration of a period of time

of five years from the date of the entry into force of the agreement – on

terminate the agreement through diplomatic channels in writing of the other

Contracting State. In the event of such termination ends

This agreement will apply:



a) in Japan:



with respect to the income attributable to fiscal years that begin

on 1 January of the calendar year immediately following that in which the notice of termination

or later; and



b) in Sweden:



with regard to income acquired on 1 January of the calendar year

immediately following that in which the notice is given or later.



In witness whereof the undersigned, being

duly authorized by their respective Governments,

have signed this agreement.



Done at Stockholm on 21 January 1983 in duplicate in

English language.



For the Government of Sweden:



Lennart Bodström



For the Government of Japan:



Wataru Owada

Law (2014:374).