dtc agreement between sweden and netherlands

8/2/2019 DTC agreement between Sweden and Netherlands

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30 (1991) N r . 1 :'

TRACTATENBLADV A N HET

KONI NKRI JK DER NEDE RL AN DE NJAARGANG 1991 Nr. 108

A. TITELOvereenkomst tussen hetKoninkrijk derNederlanden en hetKoninkrijk Zweden tot het vermijden vandubbele belasting en hetvoorkomen van het ontgaan van belasting met betrekking tot belastingennaar het inkomen ennaar het vermogen, met Protocol;Stockholm, 18 juni 1991

B . T E K S T

Con vention between the Kingdom of the Netherland s and the Kingdom ofSweden forthe avoidance ofdoub le taxation and the prevention of fiscalevasion with respect to taxes on income and on capital

The Government of the Kingdom of the Netherlands,andthe Government of the Kingdom of Sweden,Desiring to replace by a newConvention theexisting Conventionbetween the Kingdom of the Netherlands and the Kingdom ofSweden for the avoidance of double taxation and for the establish-ment of rules for reciprocal administrative assistance with respect totaxes on income and on capital, signed at The Hague on 12 March1968,Have agreed as follows:


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CHAPTER ISCOPE OF THE CONVENTION

Article 1Personal scope

This Con vention shall apply to persons w ho are residents of one orboth of the Contracting States.Article 2

Taxes covered1. This Convention shall apply to taxes on income and on capitalimposed on behalf of a Contracting State or of its political subdivi-sions or local auth oritie s, irrespective of the m ann er in which they arelevied.2. There shall be regarded as taxes on income and on capital alltaxes imposed on total income, on total capital, or on elements of

incom e or of capital, including taxes on gains from the alienation ofmovable or immovable property, as well as taxes on capital appreci-ation.3 . The existing taxes to which the Convention shall apply are inparticular:a) in Sw eden:- the State income tax (den statliga inkom stskatten), including thesailors' tax (sjdmansskatten) and the coupon tax (kupongskatten),- the tax on public entertainers (bevillningsavgiften for vissa

offentliga forestallningar),- the real estate tax (den statliga fastighetsskatten),- the communal income tax (den kommunala inkomstskatten),- the State capital tax (den statliga form ogenh etsskatten)hereinafter referred to as "Swedish tax");b) in the N etherla nds:- de inkom stenbelasting (Incom e tax),- de loonbelasting (wages tax),- de venno otschapsb elasting (company tax) including the Govern-ment share in the net profits of the exploitation of natural resourceslevied pursuant to the Mijnwet 1810 (the Mining Act of 1810) withrespect to concessions issued from 1967, or pursuant to the MijnwetCo ntine ntaal P lat 1965 (the N etherlan ds Co ntinental Shelf MiningAct of 1965),- de dividendbe lasting (dividend tax),


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- de vermogen sbelasting (capital tax)(hereinafter referred to as "Netherlands tax").4. The Co nvention shall app ly also to any identical or substantially

similar taxes which are imposed after the date of signature of theConvention in addition to, or in place of, the existing taxes. Thecom peten t autho rities of the Contrac ting States shall notify each othe rof any substantial changes which h ave been m ade in their respectivetaxation laws.CHAPTER 11

DEFINITIONS

Article 3General definitions

1. For the purposes of this Convention, unless the context other-wise requires:a) the term "Sw ede n" means the Kingdom of Sweden and, whenused in a geographical sense, includes the national territory, theterritorial sea of Sweden as well as other maritime areas over whichSweden in accordance with international law exercises sovereignrights or jurisdiction;b) the term "the N etherla nds " means the part of the Kingdom ofthe Netherlands that is situated in Europe including the part of thesea-bed and its subsoil und er the N orth Sea, to the exten t that this areain accordance with international law has been or may hereafter bedesignated under Netherlands laws as an area within which theNethe rland s m ay exercise sovereign rights with respect to the explora-tion and exploitation of the natural resources of the sea-bed or itssubsoil;c) the terms "a Contracting State" and "the other ContractingState" mean Sweden or the Netherlands, as the context requires; theterm "the Contracting States" means Sweden and the Netherlands;d) the term "person" includes an individual, a company and anybody of persons;e) the term "c om pa ny " m eans any bod y corporate or any entitywhich is treated as a body corporate for tax purposes;f) the terms "enterprise of a Co ntracting State" and "enterprise ofthe other Contracting State" mean respectively an enterprise carriedon by a resident of a Contracting State and an enterprise carried on bya resident of the other Contracting State;g) the term " interna tional traffic" m eans any transpo rt by a ship oraircraft operated by an enterprise which has its place of effective


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m anagem ent in a Con tracting S tate, except when the ship or aircraft isoperated solely between places in the other Contracting State;h) the term "n atio nal " me ans:1. any individual possessing the nationality of a ContractingState;2. any legal person, partnership and association deriving itsstatus as such from the laws in force in a Co ntrac ting S tate ;i) the term "com petent autho rity" m eans :1. in Sweden, the Minister of Financ e, his autho rized represen-tative or the authority which is designated as a competentauthority for the purpo ses of this Co nv entio n;2. in the Netherlands, the Minister of Finance or his dulyauthorized representative.2. As regards the application of the Convention by a ContractingState, any term not defined therein shall, unless the context otherwiserequires, have the meaning which it has under the law of that Stateconcerning the taxes to which the Convention applies.

Article 4

Resident1. For the purposes of this Convention, the term "resident of aContracting State" means any person who, under the laws of thatState, is liable to tax therein by rea son of his domicile, residence, placeof management or any other criterion of a similar nature, provided,however, that this term does not include any person who is liable to taxin that State in respect only of income from sources in that State orcapital situated therein.2. W here by reason of the provisions of para grap h (1) an individualis a resident of both Contracting States, then his status shall bedetermined as follows:a) he shall be deem ed to be a resident of the State in which he has apermanent home available to him; if he has a permanent homeavailable to him in both States, he shall be deemed to be a resident ofthe State with which his personal and economic relations are closer(centre of vital interests);b) if the State in which he has his centre of vital interests can no t bedetermined, or if he has not a permanent home available to him in

either State, he shall be deemed to be a resident of the State in which hehas an habitual abode;c) if he has an habitua l ab ode in bo th States or in neithe r of them ,he shall be deemed to be a resident of the State of which he is anational;


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d) if he is a national of both States or of neither of them, thecompetent authorities of the Contracting States shall settle thequestion by mutual agreement.3 . Where by reason of the provisions of paragraph (1) a personother than an individual is a resident of both Con tracting S tates, thenit shall be deemed to be a resident of the State in which its place ofeffective management is situated.

Article 5Permanent establishment

1. For the purposes of this Convention, the term "permanentestablishmenfmeans a fixed place of business through which thebusiness of an enterprise is wholly or partly carried on.2.a)b)c)d)e)0extra

The term "permanent establishment" includes especially:a place of m anagem ent;ab ranch ;an office;a factory;a workshop; anda mine, an oil or gas well, a quarry or any other place ofction of natural resources.

3 . A building site or cons truction or installation p roject constitutesa permanent establishment only if it lasts more than 12 months.4. Notwithstanding the preceding provisions of this Article, theterm "permanent establishment" shall be deemed not to include:a) the use of facilities solely for the purp ose of storag e, display o rdelivery of goods or merchandise belonging to the enterprise;b) the m aintenan ce of a stock of goods or m erchand ise belongingto the enterprise solely for the purp ose of storage, display or d elivery;c) the m aintenan ce of a stock of goods or m erchand ise belongingto the enterprise solely for the purpose of processing by anotherenterprise;d) the maintenance of a fixed place of business solely for thepurp ose of purch asing goo ds or merchan dise or of collecting informa-tion, for the enterprise;e) the maintenance of a fixed place of business solely for thepurpose of carrying on, for the enterprise, any other activity of a

preparatory or auxiliary character;f) the main tenanc e of a fixed place of business solely for anycombination of activities mentioned in sub-paragraphs (a) to (e),provided that the overall activity of the fixed place of businessresulting from this combination is of a preparatory or auxiliarycharacter.


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5. N otwithstand ing the provisions of paragraph s (1) and (2), wherea person - other than an agent of an independent status to whomparagraph (6) applies - is acting on behalf of an enterprise and has,and habitually exercises, in a Contracting State an authority tocon clude co ntracts in the nam e of the enterprise, that enterprise sh allbe deemed to have a permanent establishment in that State in respectof any activities which that person undertakes for the enterprise,unless the activities of such person are limited to those mentioned inparagraph (4) which, if exercised through a fixed place of business,would not make this fixed place of business a permanent establish-ment under the provisions of that paragraph.

6. An enterprise shall not be deem ed to have a pe rm ane nt establish-ment in a Contracting State merely because it carries on business inthat State through a broker, general commission agent or any otheragent of an ind epen dent status, provided that such persons are actingin the ordinary course of their business.

7. The fact that a company which is a resident of a ContractingState controls or is controlled by a comp any w hich is a resident of theother Contracting State, or which carries on business in that otherState (wh ether through a perm anen t establishmen t or otherwise), shallnot of itself constitute either company a permanent establishment ofthe other.

CHAPTER IIITAXATION OF INCOME

Article 6Income from immovable property

1. Income derived by a resident of a Contracting State fromimmovable property (including income from agriculture or forestry)situated in the other Contracting State may be taxed in that otherState.2. The term "im m ovable p rop erty " shall have the meaning which ithas under the law of the Contracting State in which the property inquestion is situated. The term shall in any case include propertyaccessory to immovable property, livestock and equipment used in

agriculture and forestry, rights to which the provisions of general lawrespecting landed property apply, buildings, usufruct of immovablepro perty and rights to variable or fixed pa ym ents as considera tion forthe working of, or the right to work, mineral deposits, sources andother n atural r esou rces; ships, boa ts and aircraft shall not be regardedas immovable property.


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3. The provisions of paragraph (1) shall apply to income derivedfrom the direct use, letting, or use in any other form of immovableproperty.4. The provisions of paragraphs (1) and (3) shall also apply to theincome from imm ovable property of an enterprise and to income fromimmovable property used for the performance of independent per-sonal services.

Article 7Business profits

1. The profits of an enterprise of a Contracting State shall betaxable only in that State unless the enterprise carries on business inthe other Contracting State through a permanent establishmentsituated the rein . If th e enterprise carries on busin ess as aforesaid, theprofits of the enterprise may be taxed in the other State but only somuch of them as is attributable to that permanent establishment.2. Subject to the provisions of pa rag rap h (3 ), where an en terprise ofa Co ntractin g State carries on business in the other C ontracting Statethrough a permanent establishment situated therein, there shall ineach Contracting State be attributed to that perm anen t establishmentthe profits which it might be expected to mak e if it were a distinct an dsepa rate enterp rise engaged in the same or similar activities un der thesame or similar conditions and dealing wholly indep enden tly with theenterprise of which it is a permanent establishment.3 . In the determ ination of the profits of a perm ane nt establishm ent,

there shall be allowed as deductions expenses which are incurred forthe purpose s of the perm anen t establishment, including executive a ndgeneral administrative expenses so incurred, whether in the State inwhich the permanent establishment is situated or elsewhere.4 . No profits shall be attributed to a permanent establishment byreason of the mere purchase by that permanent establishment ofgoods or merchandise for the enterprise.5. Fo r the pu rposes of the preceding para grap hs, the profits to beattributed to the perman ent establishment shall be determined by the

same m ethod year by year unless there is good and sufficient reason tothe contrary.6. Where profits include items of income which are dealt withseparately in other Articles of this Conv ention , then the provisions ofthose Articles shall not be affected by the provisions of this Article.


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Article 8Shipping and air transport

1. Profits from the operation of ships or aircraft in internationaltraffic shall be taxable only in the Co ntrac ting State in which the placeof effective management of the enterprise is situated. If that Stateaccording to its legislation cannot tax the whole of the income, theincome shall be taxable only in the Contracting State of which theenterprise is a residence.2. If the place of effective management of a shipping enterprise isaboa rd a ship, then it shall be deemed to be situated in the Con tracting

State in which the home harbour of the ship is situated, or, if there isnot such hom e harbo ur, in the Contracting State of which the o perato rof the ship is a resident.3. With respect to profits derived by the air transport consortiumScandinavian Airlines System (SAS) the provisions of paragraph (1)shall apply only to such part of the profits as corresponds to theparticipation held in that consortium by AB Aero transport (AB A), theSwedish partner of Scandinavian Airlines System.4. For the purposes of this Article, profits derived from the

operation in international traffic of ships and aircraft include profitsfrom the rental on a bareboat basis of ships and aircraft operated ininternational traffic if such rental profits are incidental to the profitsdescribed in paragraph (1).5. The prov isions of pa rag rap h (1) shall also app ly to profits fromthe participation in a pool, a joint business or an internationaloperating agency.

Article 9Associated enterprises

1. Where:a) an enterprise of a Contracting State participates directly orindirectly in the m anag em ent, con trol or capital of an enterprise of theother Contracting State, orb) the same persons pa rticipa te directly or indirectly in the m an-agem ent, control or capital of an enterprise of a Co ntracting State andan enterprise of the other Contracting State,and in either case conditions are m ade or imposed between the twoente rprises in their commercial or financial relations which differ fromthose which vvould be made between independent enterprises, thenany profits which w ould , but for those con dition s, have accrued to oneof the enterprises, but, by reason of those conditions, have not so


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accrued, may be included in the profits of that enterprise and taxedaccordingly. It is understood, however, that the fact that associatedenterprises have concluded arrangements, such as costsharing ar-rangements or general services agreements, for or based on theallocation of executive, general administrative, technical and com-mercial expenses, research and development expenses and othersimilar expenses, is not in itself a cond ition as meant in the preced ingsentence.

2. W here a Co ntrac ting S tate includes in the profits of an enterpriseof tha t State - an d taxes accordingly -pro fits on which an enterprise ofthe othe r Con tracting State has been charged to tax in that other Stateand the profits so included a re profits which wo uld have accrued to theenterprise of the first-mentioned State if the conditions m ade betweenthe two enterprises had been those which would have been madebetween independent enterprises, then that other State shall make anappropriate adjustment to the amount of the tax charged therein onthose profits. In determining such a djustment, due regard shall be hadto the other provisions of this Convention and the competentauthorities of the Contracting State shall if necessary consult eachother.

Article 10Dividends

1. Dividend s paid by a comp any which is a resident of a Co ntract-ing State to a resident of the oth er Contrac ting State may be taxed inthat other State.2. Such dividends may also be taxed in the Contracting State ofwhich the company paying the dividends is a resident and accordingto the laws of that S tate, bu t if the rec ipien t is the beneficial owner of

the d ividend s the tax so charged shall not exceed 15 pe r cent of thegross am oun t of the divid end s. How ever, if the beneficial ow ner is acompany (other than a partnership) which holds directly at least 25per cent of the capital of the company paying the dividends thedividends should be exempt from tax in the Contracting State ofwhich the company paying the dividends is a resident.This paragraph shall not affect the taxation of the company inrespect of the profits out of which the dividends are paid.3. The term "dividends" are used in this Article means incomefrom shares, "jouissance" shares or "jouissance" rights, miningshares, foun ders' shares or oth er rights participatin g in profits, as wellas income from debt-claims participating in profits and income fromother corporate rights which is subjected to the same taxationtreatm ent as incom e from shares by the laws of the State of which thecompany making the distribution is a resident.


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4. The provisions of paragraphs (1) and (2) shall not apply if thebeneficial owner of the dividends, being a resident of a ContractingState, carries on bu siness in the other C ontracting State of which thecompany paying the dividends is a resident, through a permanentestablishment situated therein, or performs in that other State inde-pendent personal services from a fixed base situated therein, and theholding in respect of which the dividends are paid is effectivelyconnected with such perm anen t establishment or fixed bas e. In suchcase the prov isions of Article 7 or Article 14, as the case may b e, shallapply.

5. Where a company which is a resident of a Contracting Statederives profits o r incom e from the other C ontrac ting S tate, that othe rState may not impose any tax on the dividends paid by the com pany,except insofar as such dividends are paid to a resident of that otherState or insofar as the holding in respect of which the dividends arepaid is effectively connected with a permanent establishment or afixed base situated in that other State, nor subject the company'sundistributed profits to a tax on the company's undistributed profits,even if the dividend s paid or the und istributed profits consist whollyor partly of profits or income arising in such other State.

Article 11Interest

1. Interest arising in a Contracting State and paid to a resident ofthe other C ontracting State shall be taxable only in that othe r State ifsuch resident is the beneficial owner of the interest.2. The term "interest" as used in this Article means income fromdebt-claims of every kind, whethe r or not secured by mortgag e, bu t no tcarrying a right to pa rticipate in the deb tor's profits, and in pa rticular,income from government securities and income from bonds ordebentures, including premiums and prizes attaching to such se-curities, bonds or debentures. Penalty charges for late payment shallnot be regarded as interest for the purpose of this Article.3. The provisions of pa rag rap h (1) shall not apply if the beneficialowner of the interest, being a resident of a Contracting State, carrieson business in the othe r Con tracting State in which the interest arises,through a permanent establishment situated therein, or performs in

that other State independent personal services from a fixed basesituated therein, an d the debt-claim in respect of which the interest ispaid is effectively connected with such permanent establishment orfixed base. In such case the p rovisions of Article 7 or Article 14, as thecase may be, shall apply.


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4. W here, by reason of a special relationship b etween the payer andthe beneficial owner or between bo th of them and som e other p erson,the am ount of the interest, having regard to the debt-claim for w hich itis paid, exceeds the amount which would have been agreed upon bythe payer and th e beneficial owner in the absence of such relationsh ip,the provisions of this Article shall apply only to the last-mentionedamount. In such case, the excess part of the payments shall remaintaxable according to the laws of each Contracting State, due regardbeing had to the other provisions of this Convention.

Article 12Royalties

1. Royalties arising in a Co ntracting State and paid to a residen t ofthe other Contracting State shall be taxable only in that other State ifsuch resident is the beneficial owner of the royalties.2. The term "royalties" as used in this Article means payments ofany kind received as a considera tion for the use of, or the right to use,any copyright of literary, artistic or scientific work includ ing cinem a-tograph films and films or tapes for radio or television broadcasting,any patent, trade mark, design or model, plan, secret formula orprocess, or for information concerning industrial, commercial orscientific experience.3 . The provisions of paragraph (1) shall not apply if the beneficialowner of the roya lties, being a resident of a Co ntrac ting State, carrieson business in the o ther C ontrac ting State in which the royalties arise,through a permanent establishment situated therein, or performs in

that other State independent personal services from a fixed basesituated therein, and the right or property in respect of which theroyalties are paid is effectively connected with such permanentestablishm ent or fixed bas e. In such case the provisions of Article 7 orArticle 14, as the case may be, shall apply.4. W here, by reason of a special relationship between the pay er andthe beneficial ow ner or between bo th of them and som e other perso n,the amount of the royalties, having regard to the use, right orinformation for which they are paid , exceeds the am oun t which wou ld

have been agreed upon by the payer and the beneficial owner in theabsen ce of such rela tion ship , the provision s of this Article shall applyonly to the last-mentioned am ount. In such case, the excess part of thepaym ents shall rem ain taxable ac cording to the laws of each Con tract-ing State, due regard being had to the other provisions of thisConvention.


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Article 13

Capital gains1. Gains derived by a resident of a Contracting State from thealienation of imm ovable prop erty referred to in Article 6 and situatedin the other Contracting State may be taxed in that other State.2. Gains from the alienation of movable property forming part ofthe business property of a permanent establishment which an enter-prise of a Contracting State has in the other Contracting State or of

mov able prop erty pe rtaining to a fixed base av ailable to a resident of aContracting State in the other Contracting State for the purpose ofperforming ind epe nd ent perso nal services, including such gains fromthe alienation of such a permanent establishment (alone or with thewhole enterprise) or of such fixed base, may be taxed in that otherState.3. Gains from the alienation of ships or aircraft operated ininternational traffic or movable property pertaining to the operationof such ships or aircraft, shall be taxable o nly in the C ontracting State

in which the place of effective management of the enterprise issituated. If that State according to its legislation can not tax the who leof the gains, the gains shall be taxable only in the Contracting State ofwhich the alienator is a resident.With respect to gains derived by the air transport consortiumScandinavian Airlines System, the provisions of this paragraph shallapply only to such portion of the gains as corresponds to theparticipation held in that consortium by AB Aerotransport, theSwedish partner of Scandinavian Airlines System.4. Gains from the alienation of any property other than thatreferred to in paragraphs (1), (2) and (3), shall be taxable only in theContracting State of which the alienator is a resident.5. The provis ions of pa ragrap h (4) shall not affect th e right of eachof the C ontracting S tates to levy according to its own law a tax on gainsfrom the alienation of shares in a company, the capital of which iswholly or partly divided into shares a nd which u nd er the laws of tha tState is a resident of that State, derived by an individual who is aresident of the other State and has been a resident of the first-men-

tioned State in the course of the last 5 years preced ing the aliena tion ofthe shares. The provisions of this para grap h shall also apply to gainsfrom the alienation of other rights in such company which, for thepurp ose of capital gains taxa tion, are subject to the sam e treatm ent asgains from the alienation of shares by the laws of the first-mentionedState.


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Article 14

Independ ent personal services1. Inco m e derived by an individual w ho is a resident of a Contra ct-ing State in respect of professional services or other activities of anindep ende nt character shall be taxable only in that State unless he hasa fixed base regularly available to him in the other Contracting Statefor the purpos e of performing his activities. If he has such a fixed base,the income may be taxed in the other State but only so much thereof asis attributable to that fixed base.2. Th e term "professional services" includes especially indepe nd-ent scientific, literary, artistic, educational or teaching activities aswell as the independent activities of physicians, lawyers, engineers,architects, dentists and accountants.

Article 15

Dependent personal services1. Subject to the provisions of Articles 16, 18, 19 and 20, salaries,wages and other similar remuneration derived by a resident of aCo ntracting State in respec t of an em ploym ent shall be taxab le only inthat State unless the em ployment is exercised in the other Co ntractingState. If the employment is so exercised, such remuneration as isderived therefrom may be taxed in that other State.2. N otw ithstanding the provisions of parag raph (1), remu nerationderived by a resident of a Contracting State in respect of anemployment exercised in the other Contracting State shall be taxableonly in the first-mentioned State if:a) the recipient is presen t in the other State for a period or perio dsnot exceeding in the aggregate 183 days within any period of12 months; andb) the rem une ration is paid by, or on behalf of, an em ployer who isnot a resident of the other State; andc) the rem uneration is not borne by a perm anent establishment or a

fixed base which the employer has in the other State.3. Notwithstanding the preceding provisions of this Article, re-muneration derived by a resident of a Contracting State in respect ofan employment exercised aboard a ship or aircraft operated ininternational traffic, shall be taxable only in that State.


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Article 16Directors' fees

Directors' fees and other payments derived by a resident of aContracting State in his capacity as a member of the board ofdirectors, a "be stuu rde r" or a "com m issaris" of a company which is aresident of the other Contracting State may be taxed in that otherState.Article 17

Entertainers and sportsmen1. N otw ithstand ing th e provisions of Articles 14 and 15, incom ederived by a resident of a Con tractin g State as an entertainer, such as atheatre , motion picture , radio or television artiste, or a musician, or asa sportsm an, from his personal activities as such exercised in the othe rContracting State, may be taxed in that other State.2. Where income in respect of personal activities exercised by anentertainer or a sportsman in his capacity as such accrues not to theentertainer or sportsman himself but to another person, that incomemay, notw ithstandin g th e provisions of Articles 7,14 and 15, be taxedin the Contracting State in which the activities of the entertainer orsportsman are exercised.

Article 18Pensions, annu ities and social security payments

1. Subject to the provision s of pa rag rap h (2) of Article 19, pensionsand other similar remuneration paid to a resident of a ContractingState in consideration of past employment and any annuity shall betaxable only in that State.2. How ever, wh ere such rem une ration is not of a periodical natur eand it is paid in consideration of past employment exercised in theother Contracting State, or where instead of the right to annuities alum p sum is paid, this rem uneration or this lump sum m ay be taxed inthe Contracting State in which it arises.3. Any pension and o ther paymen t paid out un de r the provisions ofa social security system of a Contrac ting State to a resident of the other

Contracting State may be taxed in the first-mentioned State.4. The term "annuity" means a stated sum payable periodically atstated times during life or during a specified or ascertainab le perio d oftime unde r an obligation to ma ke the paym ents in return for ad equ ateand full consideration in money or money's worth.


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Article 19Governm ent service

1. a) Remuneration, other than a pension, paid by a ContractingState or a political subdivision or a local authority thereof to anindividua l in respect of services rendere d to tha t State or subdivisionor authority may be taxed in that State.b) How ever, such remune ration shall be taxable only in the otherContracting State if the services are rendered in that other State andthe individual is a resident of that State who:(i) is a nation al of that S tate; or(ii) did not becom e a resident of that S tate solely for the pu rpo se ofrende ring the services.2. a) Any pension pa id by, or out of funds created by, a Co ntract-ing State or a political subdivision or a local authority thereof to anindividual in respect of services rendered to that State or subdivisionor authority may be taxed in that State.b) However, such pension shall be taxable only in the otherCo ntracting State if the individ ual is a resident of, a nd a national of,that State.3. The provisions of Articles 15,16 and 18 shall apply to rem unera -tion and pens ions in respect of services rendere d in connection w ith abusiness ca rried on by a Contrac ting S tate or a political subdivision ora local authority thereof.

Article 20Professors and teachers

1. Payments which a professor or teacher who is a resident of aContracting State and who, at the invitation of a university, college,school or other approved educational institution, is present in theother Contracting State for the purpose of teaching or scientificresearch for a maximum period of two years, receives for suchteaching or research, shall be taxable only in the first-mentioned State.

2. This Article shall not apply to income from research if suchresearch is undertaken not in the public interest but primarily for theprivate benefit of a specific person or persons.


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Article 21Students

Payments which a student or business apprentice who is or wasimm ediately before visiting a Contrac ting State a resident of the o therContracting State and who is present in the first-mentioned Statesolely for the purpose of his education or training receives for thepurp ose of his maintena nce, education ortra inin g shall not be taxed inthat State, provided that such payments arise from sources outsidethat State.Article 22

Other income1. Items of income of a resident of a Contracting State, whereverarising, not dealt with in the foregoing Articles of this Conventionshall be taxable only in that State.2. The provisions of parag rap h (1) shall not apply to incom e, otherthan income from immovable property as defined in paragraph (2) ofArticle 6, if the recipient of such income, being a resident of a

Contracting State, carries on business in the other Contracting Statethrough a permanent establishment situated therein, or performs inthat other State independent personal services from a fixed basesituated therein, and the right or property in respect of which theincom e is paid is effectively connected with such perm anent establish-ment or fixed base. In such case the provisions of Article 7 or Arti-cle 14, as the case may be, shall apply.CHAPTER IV

T AXAT ION OF C APIT ALArticle 23

Capital1. Capital represented by immovable property referred to in Arti-cle 6, owned by a resident of a Contracting State and situated in theother Contracting State, may be taxed in that other State.2. Capital represented by movable property forming part of thebusiness property of a permanent establishment which an enterpriseof a Con tracting State has in the othe r Contracting State or by m ovableproperty pertaining to a fixed base available to a resident of aContracting State in the other Contracting State for the purpose of


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performing indep end ent p ersonal services, may be taxed in that otherState.3. Capital represented by ships and aircraft operated in interna-tional traffic and by movable property pertaining to the operation ofsuch ships and aircraft, shall be taxable only in the Contracting Statein which the place of effective management of the enterprise issituated . If tha t State accordin g to its legislation cann ot tax the wh oleof the cap ital, the capital shall be taxab le only in the Con tracting Stateof which the enterprise is a resident. For the purposes of thispara grap h the provisions of para grap h (2) of Article 8 shall apply.4. All other elem ents of capital of a resident of a Con tractin g Stateshall be taxable only in that State.

CHAPTER VELIMINATION OF DOUBLE TAXATION

Article 24Elimination of double taxation

1. In the case of Sweden, double taxation shall be avoided asfollows:a) Where a resident of Sweden derives income which under thelaws of the N etherlan ds and in accord ance with the provisions of thisConvention may be taxed in the Netherlands, Sweden shall allow -subject to the provisions of the law of Sweden concerning credit forforeign tax (as it may be ame nde d from time to time without chang ingthe general principle hereof) - as a deduction from the tax on suchincome, an amount equal to the Netherlands tax paid in respect ofsuch income.b) W here a resident of Sweden owns capital which, un de r the lawsof the Netherlands and in accordance with the provisions of thisCo nvention, may be taxed in the Ne therlan ds, Sweden shall allow as adeduction from the tax on such capital an amou nt equal to the capitaltax paid in the Neth erland s in respect of such capital. Such deductionshall not, however, exceed that part of the Swedish capital tax ascomputed before the deduction is given, which is appropriate to thecapital which may be taxed in the Netherlands.c) Notwithstanding the provisions of sub-paragraph (a) of thisparagraph, where a resident of Sweden derives income, which inacco rdan ce w ith the provisions of para gra ph (3) of Article 18 or Arti-cle 19 may be taxed in the Netherlands, Sweden shall exempt suchincome from tax.d) Notwithstanding the provisions of sub-paragraph (a) of thisparagraph, dividends paid by a company which is a resident of the


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Netherlands to a company which is a resident of Sweden shall beexempt from Swedish tax to the extent that the dividends w ould havebeen exem pt under Swedish law if both com panies had been Sw edishcompanies. This exemption shall not apply unless(i) the profits out of which the dividends are paid have, in theNe therlan ds o r elsewhere, been subjected to a tax correspon d-ing to at least 15 per cent of the net profits calculated inaccordance with Swedish law , or(ii) these dividends represent income or capital gains that wouldhave been exempt from Swedish tax if derived directly by thecom pany resident in Sweden, or(iii) these dividends represent capital gains from the alienation ofshares in a company in so far as the assets of that company, ifalienated, would yield a capital gain which, if received directlyby the Swedish company, would have been exempt fromSwedish tax, or(iv) these dividends represent capital gains from the alienation ofshares in a com pany which is a resident of the N ethe rland s, inso far as the assets of this com pany do not directly or indirectlyconsist of a perma nent establishment or imm ovable property ina third State , or of shares in a com pany which is a residen t of athird State and in so far as the profits w ithheld by this com pan ydo not represent income or capital gains derived from suchassets.However, in the case where dividends - which would have beenexempt under Swedish law if both companies had been Swedishcompanies - do not qualify for the exemption from Swedish tax,Sweden shall - in addition to the deduction from tax as mentioned insub-paragraph (a) - allow as a deduction from the tax on suchdividends an am oun t equal to 10 per cent of the gross am oun t of suchdividends.e) Where a resident of Sweden derives income which shall be

exem pt from Swedish tax in acco rdance w ith sub-p aragra ph (c) of thisparagraph or which shall be taxable only in the Netherlands ac-cording to parag raph (1) or Article 8, Sweden may, when determiningthe gradua ted rate of Swedish tax, take into account the income w hichshall be exempt from Swedish tax or which shall be taxable only in theNetherlands.2. The Netherlands, when imposing tax on its residents, mayinclude in the basis upon which such taxes are imposed the items ofincome or capital w hich, according to the provisions of this C onven-tion, may be taxed in Sweden.3 . However, where a resident of the Netherlands derives items ofincom e or owns items of capital which accord ing to A rticle 6, Article 7,para grap h (4) of Article 10, par agra ph (3) of Article 11, para grap h (3)of Article 12, pa ragraphs (1) and (2) of Article 13, Article 14,


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pa rag rap h (1) of Article 15, pa rag rap h (3) of Article 18, par agrap hs (1)(sub-paragraph a) and (2) (sub-paragraph a) of Article 19 andpara grap hs (1) and (2) of Article 23 of this Conv ention may be taxed inSw eden and a re included in the basis referred to in pa rag rap h (2), theN eth erla nd s shall exem pt such items of incom e or capital by allowinga reduction of its tax. This redu ction sh all be com puted in conformitywith the provisions of Netherlands law for the avoidance of doubletaxa tion . For that purp ose the said items of incom e or capital shall bedeemed to be included in the total amount of the items of income orcapital which are exempt from Netherlands tax under those provi-sions.

4. Further, the Netherlands shall allow a deduction from theN etherlands tax so com puted for the items of income which accordingto pa rag rap h (2) of Article 10, pa rag rap h (5) of Article 13, Article 16,Article 17 and p ara gra ph (2) of Article 18 of this Con ven tion m ay betaxed in Sweden to the extent that these items are includ ed in the basisreferred to in paragraph (2). The amount of this deduction shall beequa l to the tax paid in Sw eden on these items of incom e, but shall no texceed the amount of the reduction which would be allowed if theitems of incom e so included were the sole items of income which areexempt from Netherlands tax under the provisions of Netherlandslaw for the avoidance of double taxation.

C H A P T E R V IOFFSHORE ACTIVITIES

Article 25Offshore activities

1. The provisions of this Article shall apply notwithstanding anyother provisions of this Convention. However, this Article shall notapply w here offshore activities of a person constitute for that p erson apermanent establishment under the provisions of Article 5 or a fixedbase under the provisions of Article 14.2. In this Article the term "offshore activities" means activitieswhich are carried on offshore in connection with the exploration orexp loitation of the sea-bed and its subsoil and their natu ral resources,situated in one of the States.3 . An enterprise of a Contracting State which carries on offshoreactivities in the other C ontractin g S tate shall, subject to pa rag rap h (4)of this Article, be deemed to be carrying on, in respect of thoseactivities, business in that oth er State throu gh a perma nen t establish-ment situated therein, unless the offshore activities in question are


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carried on in the other State for a period or periods not exceeding inthe aggregate 30 days in any period of 12 m on ths. For the pu rpo se ofthis paragraph:a) wh ere an enterprise carrying on offshore activities in the o therContracting State is associated with another enterprise and that otherenterprise continues, as part of the same project, the same offshoreactivities that are or were being carried on by the first-mentionedenterprise, and the afore-mentioned activities carried on by bothenterprises - when added together - exceed a period of 30 days, theneach enterprise shall be deemed to be carrying on its activities for aperiod exceeding 30 days in a 12 months period;b) an enterprise shall be regarded as associated with anotherenterprise if one holds directly or indirectly at least one third of the

capital of the other enterp rise or if a person hold s directly or indirectlyat least one third of the capital of both enterprises.4. However, for the purpose of paragraph (3) of this Article theterm "offshore activities" shall be deemed not to include:a) one or any combination of the activities mentioned in para-graph (4) of Article 5;b) towing or anc ho r handling by ships primarily designed for thatpurpose and any other activities performed by such ships;c) the transport of supplies or personnel by ships or aircraft ininternational traffic.5. A resident of a Contracting State who carries on offshoreactivities in the other State, which consist of professional services o rother activities of an independent character, shall be deemed to beperforming those activities from a fixed base in the other State if theoffshore activities in question last for a continu ous p eriod of 30 daysor more.6. Salaries, wages and other similar remuneration derived by aresident of a Co ntracting State in respect of an em ployme nt connec tedwith offshore activities carried on through a perm ane nt establishm entin the other C ontracting State may, to the extent that the emp loymentis exercised offshore in that other State, be taxed in that other State.7. W here documen tary evidence is prod uced tha t tax has been paidin Sweden on the items of income m ay be taxed in Sweden according

to Article 7 and Article 14 in connection with respectively paragraph(3) and pa rag rap h (5) of this Article and pa rag rap h (6) of this Article,the Netherlands shall allow a reduction of its tax, which shall becomputed in conformity with the rules laid down in paragraph (3) ofArticle 24.


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4. The competent authorities of the Contracting States may com-municate with each other directly for the purpose of reaching anagreement in the sense of the preceding paragraphs.5. The competent authorities of the Contracting State may bymutual agreement settle the mode of application of the limitationsreferred to in Articles 10, 11 and 12.

Article 28Exchange of information

1. The competent authorities of the Contracting State shall ex-change such information as is necessary for carrying out the provi-sions of this Convention or of the domestic laws of the ContractingState concerning taxes covered by the Convention insofar as thetaxation thereunder is not contrary to the Convention. The exchangeof inform ation is no t restricted by Article 1. Any inform ation receivedby a Contracting State shall be treated as secret in the same m anne r asinformation obtained under the domestic laws of that State and shallbe disclosed only to persons or authorities (including courts andadministrative bodies) involved in the assessment or collection of, theenforcement or prosecution in respect of, or the determination ofappeals in relation to, the taxes covered by the Convention. Suchpersons or authorities shall use the information only for suchpurpo ses. They may disclose the information in pub lic court proceed-ings or in judicial decisions.

2. In no case shall the provisions of par agra ph (1) be construed soas to impose on a Contracting State the obligation:a) to carry out administrative m easures at variance with the lawsand administrative practice of that or of the other Contracting State;b) to supply information which is not obtainab le und er the laws orin the normal course of the administration of that or of the otherContracting State;c) to supply information w hich would disclose any trade , business,industrial, commercial or professional secret or trade process, orinformation, the disclosure of which would be contrary to publicpolicy (ordre public).

Article 29Assistance in recovery

1. The Contracting States agree to lend each other assistance andsupport with a view to the collection, in accordance with theirrespective laws or administrative practice, of the taxes to which this


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Convention shall apply and of any increases, surcharges, overduepayments, interests and costs pertaining to the said taxes.2. At the request of the applicant State the requested State shall

recover tax claims of the first-mentioned State in accordance with thelaw and adm inistrative prac tice for the recovery of its own tax claims.How ever, such claims do n ot enjoy any priority in the reques ted Stateand cannot be recovered by imp risonm ent for debt of the debtor. Therequested State is not obliged to take any executory measures whichare not provided for in the laws of the applicant State.3. The provisions of paragraph (2) shall apply only to tax claimswhich form the subject of an instrument permitting their enforcementin the applicant State and, unless otherwise agreed between the

competent authorities, which are not contested.How ever, where the claim relates to a liability to tax of a person as anon resident of the applicant State, paragraph (2) shall only apply,unless otherwise agreed between the com petent au thorities, where theclaim may no longer be contested.4. The obligation to provide assistance in the recovery of tax claimsconcern ing a deceased person or his estate is limited to the value of theestate or the property acquired by each beneficiary of the estate,according to whether the claim is to be recovered from the estate or

from the beneficiaries thereof.5. The requested State shall not be obliged to accede to the req uest:a) if the applicant State has not pu rsue d all means available in itsown territory, except where recourse to such m eans w ould give rise todisproportionate difficulty;b) if" and insofar as it considers the tax claim to be con trary to theprovisions of this Convention or of any other convention to whichboth of the Contracting States are parties.6. The request for adm inistrative assistance in the recovery of a taxclaim shall be accompanied by:a) a declara tion th at the tax claim concerns a tax covered by theConvention and that the conditions of paragraph (3) are met.b) an official copy of the instrum ent perm itting enforcement in theapplicant State;c) any other docum ent required for recovery;d) where appropriate, a certified copy confirming any relateddecision emanating from an administrative body or a public court.7. The ap plican t State shall indicate the amo unts of the tax claim tobe recovered in both the currency of the applicant State and thecurrency of the requested State. The rate of exchange to be used for thepurpose of the preceding sentence is the last selling price settled on themost representative exchange market or markets of the applicantState. Each amount recovered by the requested State shall be trans-


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ferred to the app licant State in the currency of the requested State. Thetransfer shall be carried out within a perio d of a m onth from the da teof the recovery.8. At the request of the applicant State, the requested State shall,with a view to the recovery of an amount of tax, take measures ofconservancy even if the claim is contested or is not yet the subject of aninstrument permitting enforcement, in so far as such is permitted bythe laws and administrative practice of the requested State.9. The instrument permitting enforcement in the applicant Stateshall, where appropriate and in accordance with the provisions in

force in the requested State, be accepted, recognised, supplem ented orreplaced as soon as possible after the da te of the receipt of the reque stfor assistance by an instrument permitting enforcement in the re-quested State.10. Questions concerning any period beyond which a tax claimcanno t be enforced shall be governed by the law of the app licant State.The request for assistance in the recovery shall give particularsconcerning that period.11. Acts of recovery carried out by the requested S tate in p ursu anc eof a request for assistance, which, according to the laws of that State,would have the effect of suspending or interrupting the periodm entione d in para gra ph (10), shall also have this effect un de r the lawsof the app licant State. The requested State shall inform the applic antState about such acts.12. The requested State may allow deferral of paym ent or pay m ent

by installments, if its laws or adm inistrative practice pe rmit it to do soin similar circumstances; but it shall first inform the applicant State.13. The competent authorities of the Contracting States shall bycommon agreement prescribe rules concerning m inimum am ounts oftax claims subject to a request for assistance.14. The C ontracting States shall reciprocally waive any restitutionof costs resulting from the respective assistance and support whichthey lend each other in applying this Conv ention. The applican t Stateshall in any event remain responsible tow ards the requested State forthe pecuniary consequences of acts of recovery which have beenfound unjustified in respect of the reality of the tax claim conce rned orof the validity of the instrument permitting enforcement in theapplicant State.


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Article 30Diplomatic agents and consular officers

1. Nothing in this Convention shall affect the fiscal privileges ofdiplomatic agents or consular officers under the general rules ofinternational law or under the provisions of special agreements.2. For the purposes of the Convention an individual, who is ame mb er of a diplom atic or consular m ission of a Contracting State inthe other C ontrac ting S tate or in a third State and who is a national ofthe sending State, shall be deemed to be a resident of the sending Stateif he is subm itted therein to the sam e obligations in respect of taxes on

income and on capital as are residents of that State.3. The Convention shall not apply to international organisations,organs and officials thereof an d m em bers of a diplom atic or consu larmission of a third State, being present in a Contracting State, if theyare not subjected therein to the same o bligations in respect of taxes onincome or on capital as are residents of that State.Article 31

Territorial extension1. This Convention may be extended, either in its entirety or withany necessary modifications, to either or both of the countries ofAruba or the N etherlands Antilles, if the country concerned imposestaxes substan tially sim ilar in charac ter to those to which the Conven -tion app lies. Any such ex tension shall take effect from such date andsubject to such modifications and condition s, including conditions asto termination, as may be specified and agreed in notes to beexchanged through diplomatic channels.2. Unless otherwise agreed the termination of the Con vention shallnot also terminate any extension of the Convention to any country towhich it has been extended under this Article.

CHAPTER VIIIFINAL PROVISIONS

Article 32Entry into force

1. The Convention shall enter into force on the thirtieth day afterthe latter of the dates on which the respective Governments have


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notified each other in writing that the formalities constitutionallyrequired in their respective States have been complied with, and itsprovisions shall have effect for the taxable years and periods begin-ning on or after the first day of January in the calendar year nextfollowing that in which the Convention has entered into force.

2. The Convention between the Kingdom of the Netherlands andthe Kingdom of Sweden for the avoidance of double taxation and theestablishment of rules for reciprocal administrative assistance withrespect to taxes on income and on cap ital, with Protoc ol, signed at TheHa gue on 12 M arch 1968, shall term inate up on the entry into force ofthis Convention. However, the provisions of the 1968 Conventionshall continue in effect until the provisions of this Convention, inaccordance with the provisions of paragraph (1) of this Article, shallhave effect.

Article 33Termination

This Convention shall remain in force until terminated by aContracting State. Either Contracting State may terminate the Con-vention, through diplomatic channels, by giving written notice oftermination at least six months before the end of any calendar yearafter the expiration of a period of five years from the date of its entryinto force. In such event the Co nve ntion shall cease to have effect forthe taxable years and periods beginning on or after the first day ofJanuary in the calendar year next following that in which theConvention has been terminated.IN W ITNE SS W H ER EO F the undersigned, being duly authorizedthereto, have signed this C onvention.D O N E at Stockholm this 18th day of Ju ne 1991, in duplicate in theEnglish language.

For the Government of the Kingdom of the Netherlands(sd.) H. C. J. EVERAARSFor the Government of the Kingdom of Sweden(sd.) ERIK ASBRINK


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ProtocolAt the moment of signing the Convention for the avoidance of

double taxation and the prevention of fiscal evasion with respect totaxes on income and on capital, this day concluded between theKingdom of the Netherlands and the Kingdom of Sweden, theundersigned have agreed that the following provisions shall form anintegral part of the Convention.I. Ad Article 3, paragraph (1), sub-paragraph (b)It is understoo d that the term " the N ethe rland s" shall include theexclusive economic zone within which the Netherlands may exercise

sovereign rights in accordance with international law, if the Nether-lands, under Netherlands laws, will designate such a zone and willexercise taxation rights therein.II . Ad Article 3, paragraph (1), sub-paragraph (g)Tran sport of supplies or personn el between a Co ntracting S tate anda location where activities are carried on offshore in that State orbetween such location s, shall be regarded as transp ort between placesin that State.III . Ad Article 4An individual living aboard a ship without any real domicile ineither of the Contracting State shall be deemd to be a resident of theContracting State in which the ship has its home harbour.IV. Ad Articles 5, 6, 13 and 23It is understood that exploration and exploitation rights of thesea-bed and its subsoil and their natural resources shall be regarded asimm ovable property situated in the Co ntracting S tate the sea-bed an dsubsoil of which they are related to, and that these rights shall bedeemed to pertain to the property of a permanent establishment inthat State. Furthermore, it is understood that the afore-mentionedrights include rights to interests in, or to benefits of, assets to beproduced by such exploration or exploitation.V. Ad Article 7In respect of parag rap hs (1) and (2) of Article 7, where an enterp riseof a Contracting State sells goods or merchandise or carries onbusiness in the other Contracting State through a permanent estab-lishment situated the rein, the profits of that perm anen t establishmentshall not be determined on the basis of the total amount received bythe enterprise, but shall be determined only on the basis of the


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remuneration which is attributable to the actual activity of theperm ane nt estab lishm ent for such sales or busin ess. Especially, in thecase of contracts for the survey, supply, installation or construction ofindustrial, commercial or scientific equipment or premises, or ofpublic works, when th e enterprise has a perm anen t establishment, theprofits of such permanent establishment shall not be determined onthe basis of the total amount of the contract, but shall be determinedonly on the bas is of that pa rt of the con tract w hich is effectively carriedout by the perm ane nt establishment in the Con tracting State where theperm ane nt establishm ent is situated. The profits related to that part ofthe contract which is carried out by the head office of the enterpriseshall be taxa ble only in the C ontrac ting State of which the en terprise isa resident.

VI. Ad Articles 10, 11 and 12W here tax has been levied at source in excess of the am oun t of taxchargeable under the provisions of Articles 10,11 or 12, applicationsfor the refund of the excess am ou nt of tax have to be lodged w ith thecompetent authority of the Contracting State having levied the tax,within a period of three years after the exp iration of the calen dar yearin which the tax has been levied.VII. Ad Article 16It is understood that "bestuurder" or "commissaris" of a Nether-lands company means persons, who are nominated as such by thegeneral meeting of shareholders or by any other competent body ofsuch company and are charged with the general management of thecompany and the supervision thereof, respectively.VIII . Ad Article 20If the Contracting State of which a recipient referred to in para-graph (1) of Article 20 is a resident, is un able un de r its laws to tax theincome con cerned, the income shall be taxable only in the Con tractingState in which the teaching or scientific research is performed.IX . Ad Article 23This A rticle shall no t apply unles s there is a general tax on ca pital inboth Contracting States.X . Ad Article 241. It is und erstood that fort he purpo ses of parag raph (1) sub-para-graph (d) of Article 24:a) the mere fact that profits are not charged with corporate orincom e tax becau se of losses carried forward or back d oes not pre vent


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the dividends paid out of these profits to qualify for exemption fromSwedish tax;b) unless the comp any receiving the dividends requ ests otherwise,dividends will be considered firstly to have been paid out of profitswhich qualify these dividends for ex em ption from Sw edish tax, if suchprofits are available;c) incom e and capital gains derived by a com pany resident in theNetherlands before the entry into force of this Convention will up toand including 31 of December 1993 be considered to qualify thedividends to be paid out of them for exemption of Swedish tax,provided these dividends qualified for exemption under the Conven-tion between the Kingdom of the Netherlands and the Kingdom ofSweden for the avoidance of double taxation and for the establish-ment of rules for reciprocal administrative assistance with respect totaxes on income and on capital, signed at The Hague on 12 March1968.

2. It is understood that for the computation of the reductionm entioned in pa rag raph (3) of Article 24, the items of capital referredto in paragraph (1) of Article 23 shall be taken into account for thevalue thereof reduced by the value of the debts secured by mortgageon that c apital and the items of capital referred to in para grap h (2) ofArticle 23 shall be taken into acco unt for the value thereof reduced bythe value of the debts pertaining to the permanent establishment orfixed base.

IN W ITNESS W H ER EO F the undersigned, being duly authorizedthereto, have signed this Convention.DONE at Stockholm this 18th day of June 1991 in duplicate in theEnglish language.

For the G overnment of the K ingdom of the Netherlands(sd.) H. C. J. EVERAARSFor the G overnment of the Kingdom of Sweden(sd.) ERIK ASBRINK


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D. PARLEMENTDe Ov ereenkom st behoeft ingevolge artikel 91 van de Grond w et de

goedkeu ring van de Staten-Generaal, alvorens het Koninkrijk aa n deOvereenkomst kan worden gebonden.G. INWERKINGTREDING

De bepalingen van de Overeenkomst en van het Protocol zulleningevolge artikel 32, eerste lid, van de Overeenkomst, juncto hetgestelde in de preambule tot het Protocol, in werking treden op dedertigste dag na de laatste van de data waarop de onderscheidenRegeringen elkaar schriftelijk ervan in kennis hebben gesteld dat degrondw ettelijk vereiste formaliteiten in hu n onder sche iden Staten zijnvoltooid.W at het Koninkrijk der Ned erland en betreft, zal de Overeenkomstingevolge artikel 3, eerste lid, letter b, voor Nederland gelden.Ingevolge artikel 31, eerste lid, kan de O vereenkom st uitgebreidworden tot Aruba en de Nederlandse Antillen.J. GEGEVENS

Van het op 12 m aart 1968 te 's-G raven hage tot stand gekom enVerdrag tussen het Koninkrijk der Nederlanden en het KoninkrijkZw eden tot het vermijden van dubbele belasting en tot het vaststellenvan regelen van wederzijdse administratieve hulp met betrekking totde belastingen naar het inkomen en naar het vermogen, naar welkVerdrag ond er m eer wordt verwezen in de pream bule tot de onde rha-vige Overeenkom st, is de tekst geplaatst in Trb. 1968,42. Zie ook Trb.1969,41.

Uitgegeven de zevenen twintigste juli 1991.De Minister van Buitenlandse Zaken,

H. VAN DEN BROEK

dtc agreement between sweden and netherlands

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