- 1
- It is understood that for the purposes of paragraph (1) sub-paragraph (d) of Article 24:
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- a)the mere fact that profits are not charged with corporate or income tax because of losses carried forward or back does not prevent the dividends paid out of these profits to qualify for exemption from Swedish tax;
- b)unless the company receiving the dividends requests otherwise, dividends will be considered firstly to have been paid out of profits which qualify these dividends for exemption from Swedish tax, if such profits are available;
- c)income and capital gains derived by a company resident in the Netherlands before the entry into force of this Convention will up to and including 31 of December 1993 be considered to qualify the dividends to be paid out of them for exemption of Swedish tax, provided these dividends qualified for exemption under the Convention between the Kingdom of the Netherlands and the Kingdom of Sweden for the avoidance of double taxation and for the establishment of rules for reciprocal administrative assistance with respect to taxes on income and on capital, signed at The Hague on 12 March 1968.
- 2
- It is understood that for the computation of the reduction mentioned in paragraph (3) of Article 24, the items of capital referred to in paragraph (1) of Article 23 shall be taken into account for the value thereof reduced by the value of the debts secured by mortgage on that capital and the items of capital referred to in paragraph (2) of Article 23 shall be taken into account for the value thereof reduced by the value of the debts pertaining to the permanent establishment or fixed base.
