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Operations of articles 5-22, 24, of 27, of the 28 and 30 this Convention and Item 2 of the Protocol are suspended by the Russian Federation according to the Presidential decree the Russian Federation of August 8, 2023 No. 585

THE CONVENTION BETWEEN THE GOVERNMENT OF THE RUSSIAN FEDERATION AND THE GOVERNMENT OF THE KINGDOM OF SWEDEN

of June 15, 1993

About avoidance of double taxation concerning taxes on the income and the capital

(Protocol as amended of 24.05.2018)

The government of the Russian Federation and the Government of the Kingdom of Sweden, wishing to sign the Convention on avoidance of double taxation concerning taxes on the income and the capital, without creating opportunity for not taxation or the lowered taxation by means of avoidance or evasion of taxes (including by use of the schemes directed to obtaining indirectly by persons with the permanent residence in the third states of the privileges provided by this Convention),

agreed as follows:

Article 1 of Person to which the Convention is applied

1. This Convention is applied to persons who are persons with the permanent residence in one or both Contracting States.

2. If income is gained by person or through it which is considered transparent from the point of view of the taxation according to the legislation of any of Contracting States, such income will reckon as the received face with the permanent residence in the Contracting State, but only in that part in which it is considered the income of person with the permanent residence for the purposes of the tax legislation of such State.

Article 2 Taxes to which the Convention extends

1. This Convention is applied to the taxes on the income levied on behalf of each Contracting State irrespective of method of their collection.

2. All taxes levied from the total amount of the income or from separate elements of the income including taxes on the income from alienation of personal and real estate, and also the property increment value duties are considered as taxes on the income.

3. Taxes to which this Convention extends:

a) in the Russian Federation:

(i) income tax of the organizations;

(ii) income tax;

(iii) property tax of the organizations;

(iv) property tax of physical persons

(further referred to as "the Russian tax");

b) in Sweden:

(i) national income tax (den statliga inkomstskatten);

(ii) the dividend tax levied at source (kupongskatten);

(iii) the income tax for nonresidents (den sarskilda inkomstskatten for utomlands bosatta);

(iv) tax on the income of nonresidents - workers of arts and athletes (den sarskilda inkomstskatten for utomlands bosatta artister m.fl.);

(v) municipal income tax (den kommunala inkomstskatten);

(vi) capital tax (statlig formogenhetsskatt)

(further referred to as "the Swedish tax").

4. The convention is applied also to any to similar or in essence to similar taxes which will be levied after signature date of the Convention in amendment or instead of the taxes specified in Item 3. Competent authorities of Contracting States will notify each other on any essential changes in their relevant tax laws.

Article 3 General determinations

1. For the purposes of this Convention if other does not follow from context:

a) the term "Russia" means the Russian Federation and when using in geographical sense the term "Russia" includes its territory, territorial waters, and also economic zone and the continental shelf where the Russian Federation can perform the sovereign rights and jurisdiction according to rules of international law and where the tax legislation of the Russian Federation is effective;

b) the term "Sweden" means the Kingdom of Sweden and when using in geographical sense includes the national territory, territorial waters of Sweden, and also other water territories in which Sweden according to international law performs the sovereign rights and jurisdiction;

c) the terms "Contracting State" and "other Contracting State" mean Russia or Sweden, depending on context;

d) the term "person" includes the physical person, any legal entity and any other consolidation of persons created according to the laws of the Finishing speaking State and which is considered for the purposes of the taxation as the legal entity;

e) the term "company" means any corporate consolidation or any organization which for the tax purposes is considered as corporate consolidation;

f) the term "international delivery" means any transportation sea or the aircraft managed by person with the permanent residence in the Contracting State except cases when sea or the aircraft is operated only between Items in other Contracting State;

g) the term means "competent authority":

i) in Russia - the Ministry of Finance or the representative authorized by it;

ii) in Sweden - the Minister of Finance, his authorized representative or the body appointed as the competent representative for the purposes of this Convention.

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