3. Subparagraph a) of paragraph 2 shall not apply in the case of dividends paid by a U.S. Regulated
Investment Company or a Real Estate Investment Trust. Subparagraph b) of paragraph 2 shall apply in
the case of such dividends, but in the case of dividends paid by a Real Estate Investment Trust only if
the beneficial owner of the dividends is an individual holding less than 10 percent of the Real Estate
Investment Trust.
4. 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 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, 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.
5. The provisions of paragraph 2 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.
6. 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.
7. A religious, scientific, literary, educational or charitable organization which is resident in Sweden
and which 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.
8. 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
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