Tax Matters

Tax matters Sweden's tax blog

Tax matters Sweden's tax blog

Mikael Carlén wishes you a nice summer!

By Mikael Carlén, Jul 11, 2018 11:22:11 AM

Sommar_Tax_MattersThe spring has been eventful, with the Tax Agency’s proposal for a new ”exit tax” and the 2018 election being the two most discussed topics. We have been very active in the debate regarding exit tax. The proposal was presented by the Tax Agency who, at the same time, is the authority who is to ensure that the implemented proposal is actually complied with; this is not the best of combinations.

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Area of interest: Entrepreneur and SME Taxes, Corporate taxation, Value Added Taxes, customs and excise duties, Individual taxation

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New decision on the outsider rule

By Andreas Stranne och Maria Wettersten, Jun 28, 2018 11:46:17 AM

PwC-skatteradgivning-Group-outline_0002_burgundyAccording to the so-called 3:12 regulations, a part owner in a closely held company can be taxed on dividends/capital gains both as income from services and as income from capital. An exception to this major rule, where applicable, is the outsider rule. The Supreme Administrative Court has recently made a decision in an advance ruling in which the major issue was whether it is the actual ownership share or the economic outcome of the ownership which is to be seen to be decisive in determining the application of the outsider rule.

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Area of interest: Entrepreneur and SME Taxes

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The Supreme Administrative Court clarifies the terms applying in granting expert tax relief

By Gina Hedin, Jun 26, 2018 10:03:57 AM

PwC-skatteradgivning-FormThe Supreme Administrative Court (HFD) has recently determined that an individual is not to be seen to meet the conditions required to be granted expert tax relief if his or hers monthly compensation is in excess of two price base amounts during only his or hers first two years of employment and not in subsequent years of employment.

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Area of interest: Individual taxation

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Permanent stay still needs to be defined

By Magnus Westman, Jun 12, 2018 4:18:16 PM

PwC-skatteradgivning-Globe-solid_0001_maroonIn two decisions, the Supreme Administrative Court (HFD) have determined as to whether visits to Sweden are to be seen to be permanent stays for income tax purposes. HFD’s decisions provide a reply to certain questions but, unfortunately, imply that current practice and interpretation no longer applies.

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Area of interest: Individual taxation

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Tourist passes or cards are not seen to comprise a multiple use voucher

By Mikael Krantz Nordin och Johan Wahlgren, Jun 7, 2018 3:01:25 PM

PwC-skatteradgivning-Pen-1-solid_0001_maroonIn an advance ruling, The Swedish Council for Advance Tax Rulings (SRN) has stated that the provision of a pass or card entitling right to free entry to various attractions and to free utilization of transportation is to be seen to comprise the sale of a service and does not comprise the provision of a single or multiple use voucher.

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Area of interest: Value Added Taxes, customs and excise duties

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Swedish Government presents exposure draft to the Council on Legislation proposing the introduction of the concept ”economic employer” in Sweden

By Cecilia Arrhenius, May 22, 2018 12:16:06 PM

Swedish Government ”economic employer” in SwedenOn 17 May, the Swedish Government presented an exposure draft to the Council on Legislation with a proposal to introduce the concept, ”economic employer”, into Swedish tax legislation. The exposure draft is based on the memorandum presented by the Swedish Tax Agency last June. The proposal implies that a larger number of individuals employed by foreign companies will incur tax liability in Sweden. Foreign companies paying out salaries for work in Sweden will be liable to withhold tax on salaries even if they have no permanent establishment in Sweden.

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Area of interest: Individual taxation

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Proposed new tax regulations for the corporate sector

By Johan Ahlqvist och Julia Jonsson, May 18, 2018 11:04:50 AM

PwC-skatteradgivning-Capitol-solid_0002_burgundyOn May 3rd, the Swedish Government presented its proposed bill for new corporate tax regulations to the Parliament. The proposed bill essentially corresponds to the proposal in the exposure draft, which the Government had presented to the Council on Legislation on March 21st, 2018. The proposal implies a limitation to interest expense deductions for companies, and at the same time a reduced corporate tax rate. The Parliament will decide on these new rules on June 13th and the rules are proposed to come into force by January 1st, 2019.

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Area of interest: Corporate taxation

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EU Court rules on third party trade

By Anders Carlbom och Hillevi Söderberg, May 3, 2018 4:27:54 PM

EU Court rules on third party tradeThe EU Court has deemed that the rules on third party trading are applicable when a middle man in a chain transaction is registered for VAT in the country from which the goods are transported. However, the Court concludes that a tax authority in a member state can deny a company the right to apply these rules if the company in question does not fulfill the formal obligations.

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Area of interest: Value Added Taxes, customs and excise duties

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Comments and tips regarding this year’s income tax return

By Lukas Nilsson, Apr 16, 2018 3:44:41 PM

Comments and tips regarding this year’s income tax returnCompanies with the calendar year as their financial year, are to file their income tax return for 2017 on no later than 2 July (1 August with electronic reporting). We have compiled a number of comments regarding frequently asked questions arising in conjunction with preparing income tax returns.

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Area of interest: Corporate taxation

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Deduction of interest expenses – what does the Government’s proposal mean for the real estate sector?

By Peter Lindstrand, Apr 9, 2018 4:22:59 PM

PwC-skatteradgivning-House-2-solid_0002_burgundyOn March 21, the Government presented a draft referral to the Council on Legislation with a proposal intended to counteract tax planning based on interest deductions, and which is to contribute to increased neutrality in the tax system through an expansion of the tax base. In this article, we focus on the effects we see for the real estate and construction industries as regards this new proposal.

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Area of interest: Corporate taxation

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