(1) This Agreement shall be ratified; the instruments of ratification shall be exchanged at Stockholm as soon as possible.

(2) This Agreement shall enter into force one month after the exchange of the instruments of ratification and shall have effect in both Contracting States:

• (a) In the case of income tax, in respect of income accruing in periods from 1 January of the calendar year following the year in which the Agreement entered into force, and in the case of capital taxes, in respect of taxes levied on capital assets held on or after 1 January of the calendar year following the year in which the Agreement entered into force;
• (b) In the case of inheritance tax, in respect of estates of persons who died on or after 1 January of the calendar year following the year in which the Agreement entered into force, and in the case of gift tax, on gifts made on or after 1 January of that aforementioned year;
• (c) In the case of assistance proceedings undertaken on or after 1 January of the calendar year following the year in which the Agreement entered into force.

(3) By derogation from the provisions of this Agreement, the following shall apply to dividends within the meaning of Article 10, paragraph (3) between 1 January 1990 and 31 December 1991:

• (a) In the case of dividends paid by a joint stock company resident in Sweden, the rate of tax provided for in Article 9, paragraphs (3) and (4) of the Agreement of 17 April 1959 between the Federal Republic of Germany and the Kingdom of Sweden for the avoidance of double taxation with respect to taxes on income and capital and various other taxes, as amended by the protocol of 22 September 1978, shall be applied;
• (b) In the case of dividends paid by a joint stock company resident in the Federal Republic of Germany, the tax shall not exceed 10 per cent of the gross amount of the dividends.

The provisions of the this Agreement shall apply to dividends of this kind paid after 31 December 1991.

(4) Upon the entry into force of this Agreement:

• (a) The Agreement of 17 April 1959 between the Federal Republic of Germany and the Kingdom of Sweden for the avoidance of double taxation with respect to taxes on income and capital and various other taxes, as amended by the protocol of 22 September 1978,
• (b) The Agreement of 14 May 1935 between the German Empire and the Kingdom of Sweden for the avoidance of double taxation with respect to taxes on inheritance, and
• (c) The Treaty of 14 May 1935 between the Germany Empire and the Kingdom of Sweden on official and legal assistance in tax matters shall expire;

they shall, however, continue to have effect in respect of income, capital, estates, gifts and acts of assistance not covered by this Agreement.