Page:UN Treaty Series - vol 318.pdf/324
(a) The term "Japan", when used in a geographical sense, means all the territory in which the laws relating to Japanese tax are enforced.
(b) The terms "one of the contracting States" and "the other contracting State" mean Japan or Sweden, as the context requires.
(c) The term "tax" means Japanese tax or Swedish tax, as the context requires.
(d) The term "resident of Japan" means any individual who is resident in Japan for the purposes of Japanese tax and not resident in Sweden for the purposes of Swedish tax and the term "resident of Sweden" means any individual who is resident in Sweden for the purposes of Swedish tax and not resident in Japan for the purposes of Japanese tax.
(e) The terms "resident of one of the contracting States" and "resident of the other contracting State" mean a resident of Japan or a resident of Sweden, as the context requires.
(f) The term "Japanese corporation" means any corporation, including any legal entity, which has its head office in Japan and the term "Swedish corporation" means any coporation, including any legal entity, which is created or organized under the laws of Sweden and which is not a Japanese corporation.
(g) The terms "corporation of one of the contracting States" and "corporation of the other contracting State" mean a Japanese corporation or a Swedish corporation, as the context requires.
(h) The term "Japanese enterprise" means an industrial or commercial enterprise or undertaking carried on by a resident or corporation of Japan and the term "Swedish enterprise" means an industrial or commercial enterprise or undertaking carried on by a resident or corporation of Sweden.
(i) The terms "enterprise of one of the contracting States" and "enterprise of the other contracting State" mean a Japanese enterprise or a Swedish enterprise, as the context requires.
(j) The term "permanent establishment" when used with respect to an enterprise of one of the contracting States, means an office, branch, factory, warehouse or other fixed place of business, but does not include an agency unless the agent has, and habitually exercises, a general authority to negotiate and conclude contracts on behalf of the enterprise or has a stock of merchandise from which he regularly fills orders on its behalf. It may include the constant use of merely storage facilities but does not include the casual and temporary use of such facilities.
In this connection
(1) An enterprise of one of the contracting States shall not be deemed to have a permanent establishment in the other contracting State merely because