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of Japanese tax which that income bears to the entire income subject to Japanese tax. The foregoing provisions shall not, however, be construed to preclude the application of the provisions of Articles IX, XI and XII.

2. Income from sources within Japan which under the laws of Japan and in accordance with the provisions of the present Convention is subject to Japanese tax, whether directly or by deduction, shall be exempt from Swedish tax:

Provided that where such income, being income of a kind to which the provisions of Article VI, paragraphs 1 and 4 and Article VIII, paragraph 1 of the present Convention are applicable, is paid to a resident or a corporation of Sweden, Swedish tax may be charged on the gross amount of such income but the amount of Swedish tax chargeable shall be reduced by a sum not exceeding 15 percent of the amount of the income so charged.

Provided further that where the income is a dividend, to which the provisions of Article VII, paragraph 1 are applicable and the dividend is paid by a Japanese corporation to a resident of Sweden or to a Swedish corporation not exempted from Swedish tax with respect to such a dividend in accordance with the provisions of Article VII, paragraph 2, Swedish tax may be charged on the gross amount of the dividend, but the amount of Swedish tax chargeable shall be reduced by a sum not exceeding 15 percent of the amount of the dividend so charged.

3. The graduated rate of Swedish tax to be imposed on a resident of Sweden or in certain cases a Swedish corporation may be calculated as through income exempted under the present Convention were included in the amount of the total income.

The competent authorities of both contracting States shall exchange such information available under their respective tax laws in the normal course of administration as is necessary for carrying out the provisions of the present Convention or for the prevention of fraud or for the administration of statutory provisions against tax avoidance in relation to the tax. Any information so exchanged shall be treated as secret and shall not be disclosed to any person other that those, including a court, concerned with the assessment and collection of the tax or the determination of appeal in relation thereto. No information shall be exchanged which would disclose any trade, business, industrial or professional secret or any trade process.

Any taxpayer, who shows that the action of the taxation authorities of either contracting State has resulted or will result in double taxation contrary to the