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Application of the MLI to the Tax Treaty between Japan and Sweden

 The MLI enters into force for Japan on January 1, 2019, and for Sweden on October 1, 2018.
 Based on the reservations and notifications submitted by Japan on September 26, 2018 and by Sweden on June 22, 2018, the MLI applies to the tax treaty between Japan and Sweden, as described below.
 
 1. Tax treaty covered by the MLI
  - “Convention between Japan and Sweden for the Avoidance of Double Taxation and the Prevention of Fiscal
       Evasion with respect to Taxes on Income”
   Date of signature: January 21, 1983
   Date of entry into force: September 18, 1983
  - “Protocol Amending the Convention between Japan and Sweden for the Avoidance of Double Taxation and
       the Prevention of Fiscal Evasion with respect to Taxes on Income”
   Date of signature: February 19, 1999
   Date of entry into force: December 25, 1999
  - “Protocol Amending the Convention between Japan and Sweden for the Avoidance of Double Taxation and
      the Prevention of Fiscal Evasion with respect to Taxes on Income”
   Date of signature: December 5, 2013
   Date of entry into force: October 12, 2014

  2. Provisions of the MLI applicable to the tax treaty
   - Article 6(1) (Preamble language describing the intent of the Contracting Jurisdictions that the tax treaty will
        not create opportunities for non-taxation or reduced taxation)
   - Article 7(1) (Provisions that deny the benefits under the tax treaty where the principal purpose or one of the
        principal purposes of any arrangement or transaction was to obtain those benefits)
   - Article 16(1), 1st sentence (Provisions for presentation of a case of taxation not in accordance with the
        provisions of the tax treaty for a mutual agreement procedure)

  3. Entry into effect
  (a) The provisions of the MLI shall have effect in each Contracting Jurisdiction with respect to the tax
         treaty between Japan and Sweden:
   (i) in Japan:
    (aa) with respect to taxes withheld at source on amounts paid or credited to non-residents, where
               the event giving rise to such taxes occurs on or after the first day of the next calendar year that
               begins on or after 30 days after the date of receipt by the Depositary of the notification by
               Sweden that it has completed its internal procedures for the entry into effect of the provisions
               of the MLI with respect to the tax treaty with Japan; and
    (bb) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with
               respect to taxable periods beginning on or after the expiration of a period of six calendar
               months from 30 days after the date of receipt by the Depositary of the notification by Sweden
               that it has completed its internal procedures for the entry into effect of the provisions of the
               MLI with respect to the tax treaty with Japan; and
   (ii) in Sweden:
    (aa) with respect to taxes withheld at source on amounts paid or credited to non-residents, where
               the event giving rise to such taxes occurs on or after the first day of the next calendar year that
               begins on or after 30 days after the date of receipt by the Depositary of the notification by
               Sweden that it has completed its internal procedures for the entry into effect of the provisions
               of the MLI with respect to the tax treaty with Japan; and
    (bb) with respect to all other taxes levied by that Contracting Jurisdiction, for taxes levied with
               respect to taxable periods beginning on or after 1 January of the next year beginning on or after
               the expiration of a period of six calendar months from 30 days after the date of receipt by the
               Depositary of the notification by Sweden that it has completed its internal procedures for the
               entry into effect of the provisions of the MLI with respect to the tax treaty with Japan.
  (b) Notwithstanding (a), Article 16 (Mutual Agreement Procedure) shall have effect with respect to the
         tax treaty between Japan and Sweden for a case presented to the competent authority of a Contracting
         Jurisdiction on or after 30 days after the date of receipt by the Depositary of the notification by
         Sweden that it has completed its internal procedures for the entry into effect of the provisions of the
         MLI with respect to the tax treaty with Japan, except for cases that were not eligible to be presented as
         of that date under the tax treaty between Japan and Sweden prior to its modification by the MLI,
         without regard to the taxable period to which the case relates.

* A new press release will be issued once Sweden makes the above-mentioned notification.