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2. Swedish tax on the undivided estate of a deceased person shall, in so far as the income accrues to a beneficiary who is a resident of Japan, be in accordance with the provisions of Article XV allowed as a credit against Japanese tax payable in respect of that income.

1. For the purposes of the present Convention:

(a) Income derived from real property (including gains derived from the sale, transfer or exchange of such property, but not including interest from mortgages or bonds secured by real property), and royalties in respect of the operation of mines, quarries, or other natural resources shall be treated as income derived from the country in which such real property, mines, quarries, or other natural resources are situated.

(b) Income derived from the sale, transfer or exchange of ships or aircraft shall be treated as derived from the country where such ships or aircraft are registered.

(c) Income derived from the sale, transfer or exchange of a permanent establishment belonging to an enterprise of one of the contracting States but situated in the other contracting State shall be treated as income derived from the contracting State where the permanent establishment is situated.

(d) Capital gains derived from the sale, transfer or exchange of shares, bonds, debentures and similar assets shall be treated as derived from the country in which such assets are sold.

(e) Salaries, wages, or similar compensation for labour or personal services as well as compensation for professional services shall be treated as income from sources within the country where are rendered the services for which such compensation is paid.

2. Income, the source of which has not been determined by the provisions of the preceding paragraph of this Article or the preceding Articles of the present Convention, shall be deemed to be income from sources in that contracting State of which the recipient of the income is a resident or corporation.

1. Japan, in determining Japanese tax on its resident (including an individual, who is resident in Japan for the purposes of Japanese tax but also resident in Sweden for the purposes of Swedish tax) or corporation may include in the basis upon which that tax is imposed all items of income taxable under the laws of Japan. The amount of Swedish tax payable under the laws of Sweden and in accordance with the provisions of the present Convention, whether directly or by deduction, in respect of income from sources within Sweden and subject to the taxes of both contracting States shall, however, be allowed as a credit against Japanese tax payable in respect of that income, but in an amount not exceeding that proportion