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of June 15, 1993

About avoidance of double taxation concerning taxes on the income

Government of the Russian Federation and Government of the Kingdom of Sweden,

wishing to sign the Convention on avoidance of double taxation concerning taxes on the income,

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.

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:

taxes on the income and profit levied according to the Laws of the Russian Federation "About the income tax of the companies and organizations", "About the taxation of the income of banks", "About the taxation of the income from insurance activity" and "About the income tax from physical persons" (further the referred to as "Russian taxes");

b) in Sweden:

i) the national income tax (den statliga inkomstskatten), including tax on the salary for seamen (sjomansskatten), and tax on securities (kupongskatten);

ii) the specific income tax for nonresidents (sarskilda inkomstskatt for utomlands bosatta);

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

iv) real estate tax (den statliga fastighetsskatten);


v) the utility income tax (den kommunala inkomstskatten) (further the referred to as "Swedish taxes").

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.

2. In case of application of this Convention by the Contracting State any term which is not determined in the Convention has that significance which is attached to it by the legislation of this State concerning taxes to which the Convention extends if other does not follow from context.


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