PROTOCOL 

AMENDING THE CONVENTION BETWEEN 

THE GOVERNMENT OF THE UNITED STATES OF AMERICA 

AND THE GOVERNMENT OF SWEDEN 

FOR THE AVOIDANCE OF DOUBLE TAXATION AND 

THE PREVENTION OF FISCAL EVASION 

WITH RESPECT TO TAXES ON INCOME 

The Government of the United States of America and the Government of Sweden, 

desiring to amend the Convention between the Government of the United States of 

America and the Government of Sweden for the Avoidance of Double Taxation and the 

Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Stockholm on 

September 1, 1994 (hereinafter referred to as "the Convention"), 

Have agreed as follows: 
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ARTICLE I 

Article 1 (Personal Scope) of the Convention is amended by: 

a) omitting the last sentence of paragraph 4 and substituting the following sentence: 

 "Notwithstanding the other provisions of this Convention, a former citizen or 

long-term resident of the United States may, for the period of ten years following the loss 

of such status, be taxed in accordance with the laws of the United States."; and 

b) adding a new paragraph as follows: 

"6. In the case of an item of income, profit or gain derived by or through a person that 

is fiscally transparent under the laws of either Contracting State, such item shall be 

considered to be derived by a resident of a State to the extent that the item is treated for 

the purposes of the taxation law of such State as the income, profit, or gain of a resident." 

 ARTICLE II 

 Article 2 (Taxes Covered) of the Convention is amended by omitting 

subparagraph b) of paragraph 1 and substituting the following: 

 “b) in Sweden: 

 i) the national income tax; 

 ii) the withholding tax on dividends; 

 iii) the income tax on non-residents; 

 iv) the income tax on non-resident artistes and athletes; 

 v) for the purpose of paragraph 3 of this Article, the national capital 

 tax; 

 vi) the excise tax imposed on insurance premiums paid to foreign 

 insurers; and 

vii) the municipal income tax." 

ARTICLE III 

 Article 4 (Residence) of the Convention is amended by omitting paragraph 1 and 

substituting the following: 

"1. a) For the purposes of this Convention, the term "resident of a Contracting 

State" means any person who, under the laws of that State, is liable to tax therein by 
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reason of his domicile, residence, place of management, place of incorporation, or any 

other criterion of a similar nature, and also includes that State and any political 

subdivision or local authority thereof. This term, however, does not include any person 

who is liable to tax in that State in respect only of income from sources in that State or of 

profits attributable to a permanent establishment in that State. 

 b) A United States citizen or an alien lawfully admitted for permanent 

residence in the United States is a resident of the United States, but only if such person 

has a substantial presence, permanent home, or habitual abode in the United States. If 

such person is also a resident of Sweden under this paragraph, such person will also be 

treated as a United States resident under this paragraph and such person's status shall be 

determined under paragraph 2. 

 c) The term "resident of a Contracting State" includes a legal person 

organized under the laws of that Contracting State and that is generally exempt from tax 

in that State and is established and maintained in that State either: 

 i) exclusively for religious, charitable, scientific, artistic, cultural, or 

 educational purposes; or 

 ii) to provide pensions or other similar retirement benefits 

 pursuant to a plan." 

ARTICLE IV 

1. Article 10 (Dividends) of the Convention shall be omitted and the 

following shall be substituted: 

"ARTICLE 10 

Dividends 

1. Dividends paid by a company that is a resident of a Contracting State to a 

resident of the other Contracting State may be taxed in that other State. 

2. However, such dividends may also be taxed in the Contracting State of which the 

company paying the dividends is a resident, and according to the laws of that State, 

but if the beneficial owner of the dividends is a resident of the other 
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Contracting State, the tax so charged shall not exceed: 

 a) 5 percent of the gross amount of the dividends if the beneficial owner is a 

 company that owns shares representing at least 10 percent of the voting power in 

 the company paying the dividends; 

 b) 15 percent of the gross amount of the dividends in all other cases. 

This paragraph shall not affect the taxation of the company in respect of the profits out of 

which the dividends are paid. 

3. Notwithstanding the provisions of paragraph 2, such dividends shall not be taxed 

in the Contracting State of which the company paying the dividends is a resident if the 

beneficial owner is: 

 a) a company that is a resident of the other Contracting State that has 

 owned, directly or indirectly through one or more residents of either 

 Contracting State, shares representing 80 percent or more of the voting power 

 in the company paying the dividends for a 12-month period ending on the 

 date on which entitlement to the dividends is determined, and: 

 i) satisfies the conditions of clause i) or ii) of subparagraph c) of 

 paragraph 2 of Article 17 (Limitation on Benefits); 

 ii) satisfies the conditions of clauses i) and ii) of subparagraph e) 

 of paragraph 2 of Article 17, provided that the company satisfies the 

 conditions described in paragraph 4 of that Article with respect to the 

 dividends; 

 iii) is entitled to benefits with respect to the dividends under 

 paragraph 3 of Article 17; or 

 iv) has received a determination pursuant to paragraph 6 of 

 Article 17 with respect to this paragraph; or 

 b) a pension fund that is a resident of the other Contracting State, 

 provided that: 

 i) such dividends are not derived from the carrying on of a 

 trade or business by the pension fund or through an associated 

 enterprise; and 

 ii) such pension fund does not sell or make a contract to sell the 
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 holding from which such dividend is derived within two months of the 

 date such pension fund acquired such holding. 

 For the purposes of determining whether a company is entitled to benefits 

 with respect to the dividends under paragraph 3 of Article 17, within the 

 meaning of clause iii) of subparagraph a) of this paragraph, the determination 

 of whether a person owning shares, directly or indirectly, in the company 

 claiming the benefits of this Convention is an equivalent beneficiary shall be 

 made by treating such person as holding the same voting power in the 

 company paying the dividends as the company claiming the benefits holds in 

 such company. 

4. a) Subparagraph a) of paragraph 2 and subparagraph a) of paragraph 3 shall 

 not apply in the case of dividends paid by a U.S. Regulated Investment Company 

 (RIC) or a Real Estate Investment Trust (REIT). In the case of dividends paid by a 

 RIC, subparagraph b) of paragraph 2 and subparagraph b) of paragraph 3 shall 

 apply. In the case of dividends paid by a REIT, subparagraph b) of paragraph 2 and 

 subparagraph b) of paragraph 3 shall apply only if: 

i) the beneficial owner of the dividends is an individual or pension fund, 

 in either case holding an interest of not more than 10 percent in the REIT; 

ii) the dividends are paid with respect to a class of shares that is publicly 

 traded and the beneficial owner of the dividends is a person holding an 

 interest of not more than 5 percent of any class of the REIT’s shares; or 

iii) the beneficial owner of the dividends is a person holding an interest of 

 not more than 10 percent in the REIT and the REIT is diversified. 

b) For purposes of this paragraph, a REIT shall be "diversified" if the value 

 of no single interest in real property exceeds 10 percent of its total interests in real 

 property. For the purposes of this provision, foreclosure property shall not be 

 considered an interest in real property. Where a REIT holds an interest in a 

 partnership, it shall be treated as owning directly a proportion of 

 the partnership's interests in real property corresponding to its interest in the 

 partnership. 
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5. The term "dividends" as used in this Article means income from shares or other 

rights, not being debt-claims, participating in profits, as well as income from other 

corporate rights that is subjected to the same taxation treatment as income from shares by 

the laws of the State of which the company making the distribution is a resident, and 

income from arrangements, including debt obligations, carrying the right to participate in 

profits to the extent so characterized under the laws of the Contracting State in which the 

income arises as well as, in the case of the United States, contingent interest of a type that 

would not qualify as portfolio interest. 

6. The provisions of paragraphs 2 and 3 shall not apply if the beneficial owner 

of the dividends, being a resident of a Contracting State, carries on business in the 

other Contracting State, of which the company paying the dividends is a resident, 

through a permanent establishment situated therein, or performs in that other State 

independent personal services from a fixed base situated therein, and the dividends 

are attributable to such permanent establishment or fixed base. In such case, the 

provisions of Article 7 (Business Profits) or Article 14 (Independent Personal 

Services), as the case may be, shall apply. 

7. A Contracting State may not impose any tax on dividends paid by a company 

which is not a resident of that State, except insofar as: 

 a) the dividends are paid to a resident of that State; or 

 b) the dividends are attributable to a permanent establishment or a fixed base 

 situated in that State. 

8. A religious, scientific, literary, educational, or charitable organization that is 

resident in Sweden and that has received substantially all of its support from persons 

other than citizens or residents of the United States shall be exempt in the United States 

from the United States excise taxes imposed with respect to private foundations. 

9. A company that is a resident of a Contracting State and that has a permanent 

establishment in the other Contracting State, or that is subject to tax in that other 

Contracting State on items of income that may be taxed in that other State under Article 6 

(Income from Real Property) or under paragraph 1 of Article 13 (Gains), may be subject 

in that other Contracting State to a tax in addition to the tax allowable under the other 

provisions of this Convention. Such tax, however, may: 
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 a) in the case of the United States be imposed only on: 

 i) the portion of the business profits of the company attributable to 

 the permanent establishment, and 

 ii) the portion of the income referred to in the preceding sentence 

 that is subject to tax under Article 6 or paragraph 1 of Article 13, 

 that represents the "dividend equivalent amount" of those profits and 

 income; the term "dividend equivalent amount" shall, for the purposes of 

 this subparagraph, have the meaning that it has under the law of the United 

 States as it may be amended from time to time without changing the 

 general principle thereof; and 

 b) in the case of Sweden be imposed only on that portion of the income 

 described in subparagraph a) that is comparable to the amount that would be 

 distributed as a dividend by a locally incorporated subsidiary. 

10. The tax referred to in subparagraphs a) and b) of paragraph 9 shall not be imposed 

at a rate exceeding the rate specified in paragraph 2 a). In any case, it shall not be 

imposed on a company that: 

 a) satisfies the conditions of clause i) or ii) of subparagraph c) of 

 paragraph 2 of Article 17; 

 b) satisfies the conditions of clauses i) and ii) of subparagraph e) of 

 paragraph 2 of Article 17, provided that the company satisfies the conditions 

 described in paragraph 4 of that Article with respect to an item of income, 

 profit, or gain described in paragraph 9; 

 c) is entitled under paragraph 3 of Article 17 to benefits with respect to 

 an item of income, profit, or gain described in paragraph 9; or 

 d) has received a determination pursuant to paragraph 6 of Article 17 

 with respect to this paragraph. 

11. The term "pension fund" as used in this Article means any person that: 

 a) is organized under the laws of a Contracting State; 

 b) is established and maintained in that Contracting State primarily to 

 administer or provide pensions or other similar remuneration, including social 

 security payments; and 
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 c) is exempt from tax in that Contracting State with respect to the activities 

 described in subparagraph b)." 

2. Paragraph 5 of Article 24 (Non-Discrimination) shall be omitted and the following 

paragraph shall be substituted: 

 "5. Nothing in this Article shall be construed as preventing imposition of a tax 

described in paragraph 9 of Article 10 (Dividends)." 

ARTICLE V 

 Article 17 (Limitation on Benefits) of the Convention shall be omitted and 

the following Article substituted: 

"ARTICLE 17 

Limitation on Benefits 

1. A resident of a Contracting State shall be entitled to benefits otherwise accorded 

to residents of a Contracting State by this Convention only to the extent provided in this 

Article. 

2. A resident of a Contracting State shall be entitled to all the benefits of this 

Convention if the resident is: 

a) an individual; 

b) a Contracting State or any political subdivision or local authority thereof; 

c) a company, if: 

 i) its principal class of shares (and any disproportionate class of 

 shares) is regularly traded on one or more recognized stock exchanges, 

 and either: 

 A) its principal class of shares is primarily traded on a 

 recognized stock exchange located in the Contracting State of 

 which the company is a resident (or, in the case of a 

 company resident in Sweden, on a recognized stock exchange 

 located within the European Union or in any other European 

 Economic Area state or in Switzerland or, in the case of a company 

 resident in the United States, on a recognized stock exchange 
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 located in another state that is a party to the North American Free 

 Trade Agreement); or 

 B) the company’s primary place of management and control 

 is in the Contracting State of which it is a resident; or 

ii) at least 50 percent of the aggregate voting power and value of the 

shares (and at least 50 percent of any disproportionate class of shares) in 

the company are owned directly or indirectly by five or fewer companies 

entitled to benefits under clause i) of this subparagraph, provided that, in 

the case of indirect ownership, each intermediate owner is a resident of 

either Contracting State; 

d) a person described in subparagraph c) of paragraph 1 of Article 4 

(Residence), provided that, in the case of a person described in clause ii) of that 

subparagraph, either: 

i) more than 50 percent of the person’s beneficiaries, members or 

 participants are individuals resident in either Contracting State; or 

ii) the organization sponsoring such person is entitled to the 

 benefits of this Convention pursuant to this Article; or 

e) a person other than an individual, if: 

i) on at least half the days of the taxable year at least 50 percent of 

each class of shares or other beneficial interests in the person is owned, 

directly or indirectly, by residents of the Contracting State of which that 

person is a resident that are entitled to the benefits of this Convention 

under subparagraph a), subparagraph b), clause i) of subparagraph c), or 

subparagraph d) of this paragraph; and 

ii) less than 50 percent of the person’s gross income for the taxable 

year, as determined in the person's State of residence, is paid or accrued, 

directly or indirectly, to persons who are not residents of either 

Contracting State entitled to the benefits of this Convention under 

subparagraph a), subparagraph b), clause i) of subparagraph c), or 

subparagraph d) of this paragraph in the form of payments that are 

deductible for purposes of the taxes covered by this Convention in the 
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person’s State of residence (but not including arm's length payments in the 

ordinary course of business for services or tangible property and payments 

in respect of financial obligations to a bank that is not related to the 

payor). 

3. A company that is a resident of a Contracting State shall also be entitled to the 

benefits of the Convention if: 

a) at least 95 percent of the aggregate voting power and value of its shares 

 (and at least 50 percent of any disproportionate class of shares) is owned, directly 

 or indirectly, by seven or fewer persons that are equivalent beneficiaries; and 

b) less than 50 percent of the company’s gross income, as determined in the 

 company's State of residence, for the taxable year is paid or accrued, directly or 

 indirectly, to persons who are not equivalent beneficiaries, in the form of 

 payments (but not including arm's length payments in the ordinary course of 

 business for services or tangible property and payments in respect of financial 

 obligations to a bank that is not related to the payor), that are deductible for the 

 purposes of the taxes covered by this Convention in the company's State of 

 residence. 

4. a) A resident of a Contracting State will be entitled to benefits of the 

 Convention with respect to an item of income derived from the other Contracting 

 State, regardless of whether the resident is entitled to benefits under paragraph 2 

 or 3, if the resident is engaged in the active conduct of a trade or business in the 

 first-mentioned State (other than the business of making or managing investments 

 for the resident’s own account, unless these activities are banking, insurance, or 

 securities activities carried on by a bank, insurance company or registered 

 securities dealer), and the income derived from the other Contracting State is 

 derived in connection with, or is incidental to, that trade or business. 

b) If a resident of a Contracting State or any of its associated enterprises 

carries on a trade or business activity in the other Contracting State which gives 

rise to an item of income, subparagraph a) of this paragraph shall apply to such 

item only if the trade or business activity in the first-mentioned State is substantial 

in relation to the trade or business activity in the other State. Whether a trade or 
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business activity is substantial for purposes of this paragraph will be determined 

based on all the facts and circumstances. 

 c) In determining whether a person is “engaged in the active conduct of a 

 trade or business” in a Contracting State under subparagraph a) of this paragraph, 

 activities conducted by persons connected to such person shall be deemed to be 

 conducted by such person. A person shall be connected to another if one 

 possesses at least 50 percent of the beneficial interest in the other (or, in the case 

 of a company, at least 50 percent of the aggregate voting power and at least 50 

 percent of the aggregate value of the shares in the company or of the beneficial 

 equity interest in the company) or another person possesses, directly or indirectly, 

 at least 50 percent of the beneficial interest (or, in the case of a company, at least 

 50 percent of the aggregate voting power and at least 50 percent of the aggregate 

 value of the shares in the company or of the beneficial equity interest in the 

 company) in each person. In any case, a person shall be considered to be 

 connected to another if, based on all the relevant facts and circumstances, one has 

 control of the other or both are under the control of the same person or persons.

5. Notwithstanding the preceding provisions of this Article, where an enterprise of 

Sweden derives insurance premiums, interest, or royalties from the United States, and, 

pursuant to a tax convention between Sweden and a third state, the income consisting of 

such premiums, interest, or royalties is exempt from taxation in Sweden because it is 

attributable to a permanent establishment which that enterprise has in that third state, the 

tax benefits that would otherwise apply under the other provisions of the Convention will 

not apply to such income if the tax that is actually paid with respect to such income in the 

third state is less than 60 percent of the tax that would have been payable in Sweden if the 

income were earned in Sweden by the enterprise and were not attributable to the 

permanent establishment in the third state. Any interest or royalties to which the 

provisions of this paragraph apply may be taxed in the United States at a rate that shall 

not exceed 15 percent of the gross amount thereof. Any insurance premiums to which the 

provisions of this paragraph apply will be subject to tax under the provisions of the 

domestic law of the United States, notwithstanding any other provision of the 

Convention. The provisions of this paragraph shall not apply if: 
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a) in the case of interest, as defined in Article 11 (Interest), the income from 

 the United States is derived in connection with, or is incidental to, the active 

 conduct of a trade or business carried on by the permanent establishment in the 

 third state (other than the business of making, managing, or simply holding 

 investments for the enterprise’s own account, unless these activities are banking, 

 or securities activities carried on by a bank, or registered securities dealer); or 

b) in the case of royalties, as defined in Article 12 (Royalties), the royalties 

 are received as compensation for the use of, or the right to use, intangible property 

 produced or developed by the permanent establishment itself. 

6. A resident of a Contracting State that is not entitled to benefits pursuant to the 

preceding paragraphs of this Article shall, nevertheless, be granted benefits of the 

Convention if the competent authority of the other Contracting State determines that the 

establishment, acquisition, or maintenance of such person and the conduct of its 

operations did not have as one of its principal purposes the obtaining of benefits under 

the Convention. The competent authority of the other Contracting State shall consult 

with the competent authority of the first-mentioned State before denying the benefits of 

the Convention under this paragraph. 

7. For the purposes of this Article: 

a) the term "principal class of shares" means the ordinary or common shares 

 of the company, provided that such class of shares represents the majority of the 

 voting power and value of the company. If no single class of ordinary or common 

 shares represents the majority of the aggregate voting power and value of the 

 company, the "principal class of shares" are those classes that in the aggregate 

 represent a majority of the aggregate voting power and value of the company; 

b) the term "disproportionate class of shares" means any class of shares of a 

 company resident in a Contracting State that entitles the shareholder to 

 disproportionately higher participation, through dividends, redemption payments, 

 or otherwise, in the earnings generated in the other Contracting State by particular 

 assets or activities of the company when compared to its participation in overall 

 assets or activities of such company; 

c) the term "shares" shall include depository receipts thereof; 
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d) the term "recognized stock exchange" means: 

i) the NASDAQ System owned by the National Association of 

Securities Dealers, Inc. and any stock exchange registered with the U.S. 

Securities and Exchange Commission as a national securities exchange 

under the U.S. Securities Exchange Act of 1934; 

ii) the Stockholm Stock Exchange (Stockholmsbörsen), the Nordic 

Growth Market, and any other stock exchange subject to regulation by the 

Swedish Financial Supervisory Authority; 

iii) the Irish Stock Exchange and the stock exchanges of Amsterdam, 

Brussels, Copenhagen, Frankfurt, Hamburg, Helsinki, London, Madrid, 

Milan, Oslo, Paris, Reykjavik, Riga, Tallinn, Toronto, Vienna, Vilnius and 

Zurich; and 

iv) any other stock exchanges agreed upon by the competent 

authorities of the Contracting States; 

e) a class of shares is considered to be regularly traded on one or more 

 recognized stock exchanges in a taxable year if the aggregate number of shares of 

 that class traded on such stock exchange or exchanges during the preceding 

 taxable year is at least 6 percent of the average number of shares outstanding in 

 that class during that preceding taxable year; 

f) a company’s primary place of management and control will be in the 

 Contracting State of which it is a resident only if executive officers and senior 

 management employees exercise day-to-day responsibility for more of the 

 strategic, financial, and operational policy decision making for the company 

 (including its direct and indirect subsidiaries) in that State than in any other state, 

 and the staffs conduct more of the day-to-day activities necessary for preparing 

 and making those decisions in that State than in any other state; 

g) the term "equivalent beneficiary" means a resident of a member state of 

 the European Union or of any other European Economic Area state or of a party 

 to the North American Free Trade Agreement, or of Switzerland, but only if that 

 resident: 
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i) A) would be entitled to all the benefits of a comprehensive 

 tax convention between any member state of the European Union 

 or any other European Economic Area state or any party to the 

 North American Free Trade Agreement, or Switzerland, and the 

 State from which the benefits of this Convention are claimed under 

 provisions analogous to subparagraph a), subparagraph b), clause i) 

 of subparagraph c) or subparagraph d) of paragraph 2, provided 

 that if such convention does not contain a comprehensive 

 limitation on benefits provision, the resident would be entitled to 

 the benefits of this Convention by reason of subparagraph a), 

 subparagraph b), clause i) of subparagraph c), or subparagraph d) 

 of paragraph 2 if such person were a resident of one of the 

 Contracting States under Article 4 (Residence); and 

B) with respect to insurance premiums and to income referred 

to in Article 10 (Dividends), 11 (Interest), or 12 (Royalties), would 

be entitled under such convention to a rate of tax with respect to 

the item of income for which benefits are being claimed under this 

Convention that is at least as low as the rate applicable under this 

Convention; or 

ii) is a resident of a Contracting State that is entitled to the benefits of 

this Convention by reason of subparagraph a), subparagraph b), clause i) 

of subparagraph c), or subparagraph d) of paragraph 2; 

h) with respect to dividends, interest, or royalties arising in Sweden 

and beneficially owned by a company that is a resident of the United States, a 

company that is a resident of a member state of the European Union will be 

treated as satisfying the requirements of subparagraph g) i) B) for purposes of 

determining whether such United States resident is entitled to benefits under this 

paragraph if a payment of dividends, interest, or royalties arising in Sweden and 

paid directly to such resident of a member state of the European Union would 

have been exempt from tax pursuant to any directive of the European Union, 

notwithstanding that the tax convention between Sweden and that other member 
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state of the European Union would provide for a higher rate of tax with respect to 

such payment than the rate of tax applicable to such United States company under 

Article 10, 11, or 12." 

ARTICLE VI 

 Article 20 (Government Service) shall be amended by adding the following new 

paragraph: 

"4. Notwithstanding paragraph 2, Sweden shall not tax a pension, paid by the U.S. 

Government to Swedish citizens and residents (and those beneficiaries entitled to 

survivors benefits), if the relevant individual was hired prior to 1978 by the U.S. 

Government to work for the United States embassy in Stockholm or the United States 

consulate general in Gothenburg and was covered under the United States Civil Service 

Retirement pension plan." 

ARTICLE VII 

 Article 23 (Relief from Double Taxation) of the Convention shall be amended by: 

a) adding the words "or former citizen or former long-term resident" after the words 

"United States citizen" both in the chapeau to paragraph 3 and at the very end of 

subparagraph a) of paragraph 3; and 

b) adding the words "or former citizenship or former long-term residency" after the 

word "citizenship" in clause (i) of subparagraph a) of paragraph 4. 

ARTICLE VIII 

1. This Protocol shall be subject to ratification in accordance with the applicable 

procedures of each Contracting State. Each Contracting State shall notify the other 

through the diplomatic channel, accompanied by an instrument of ratification, when it has 

completed the required procedures. 

2. This Protocol shall enter into force on the 30th day after the later of the 

notifications, accompanied by an instrument of ratification, referred to in paragraph 1, 

and its provisions shall have effect: 

 a) in the case of the United States: 
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 i) in respect of taxes withheld at source, for amounts paid or 

 credited on or after the first day of the second month next 

 following the date on which the Protocol enters into force; 

 ii) in respect of other taxes, for taxable years beginning on or 

 after the first day of January next following the date on which the 

 Protocol enters into force; 

 b) in the case of Sweden: 

 i) in respect of the taxes on income covered by Article VI, for 

 income derived on or after January 1, 1996; 

 ii) in respect of taxes withheld at source, for amounts paid or 

 credited on or after the first day of the second month next 

 following the date on which the Protocol enters into force; 

 iii) in respect of other taxes, for taxable years beginning on 

 or after the first day of January next following the date on which 

 the Protocol enters into force. 

3. This Protocol shall remain in effect as long as the Convention remains in force. 

IN WITNESS WHEREOF the undersigned, duly authorized thereto by their respective 

Governments, have signed this Protocol. 

DONE in duplicate at Washington on the day of September, 2005, in the English 

language. 

FOR THE GOVERMENT OF THE FOR THE GOVERNMENT OF 

UNITED STATES OF AMERICA SWEDEN