Article VII

1. Paragraphs 1, 2 and 3 of Article 10 (Dividends) of the Convention shall be deleted and replaced by the following:

"1. Dividends paid by a company which is a resident of a Contracting State, or by an investment fund which is established in 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, and according to the laws of, the Contracting State of which the company paying the dividends is a resident, or in the case of an investment fund, in, and according to the laws of, the Contracting State under the laws of which it is established, but if the beneficial owner of the dividends is a resident of the other Contracting State, the tax so charged shall not exceed:

(a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company (other than a partnership) which holds directly at least 10 per cent of the capital of the company paying the dividends (other than a paying company that is an investment fund) and this holding amounts to at least 80 000 euros or an equivalent amount in any other currency at the moment of the actual distribution of the dividends;

(b) 15 per cent 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. The term "dividends" as used in this Article means income from shares, mining shares, founders' shares or other rights, not being debt-claims, participating in profits, as well as income from other corporate rights which 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. This term also means any payments on units of investment funds."

<< Article VI		>> Article VIII
	Protocol Amending the Convention Between the Government of the Russian Federation and the Government of the Kingdom of Sweden...