In June, the Government submitted a draft legislative referral that included, among other things, more generous rules on the Swedish expert tax relief. The changes are proposed to enter into force on 1 January 2027.
In June 2023, the Government appointed an inquiry to review the current tax rules regarding the Swedish expert tax relief. The Government's proposal is largely based on the inquiry's recommendations, although some adjustments have been made. Below, we outline the proposals presented in the Council on Legislation referral.
Present rules
A foreign national who comes to Sweden to reside and work for a Swedish employer may obtain expert tax relief based on the salary level or on the nature of their duties and expertise.
When applying expert tax relief on the basis of the compensation the monthly salary must be above 1.5 times the price base amount (SEK 59,200 for 2026). This means that the monthly salary including benefits must be at least SEK 88,801 for applications filed during 2026.
Those who apply for expert tax relief due to the nature of their duties and expertise (do not fulfill the salary level), that is as an “expert,” “researcher,” or “other key person”, must fulfill certain criteria. If applying as an “expert” the employee must have specialist duties with such a focus or such a level of competence that it entails significant difficulties to recruit within Sweden. There must be a high level of specialization or unusual focus, preferably in a technically advanced or knowledge-intensive field. To qualify as “other key person,” the employee must have executive/management duties, for example as a Chief Executive Officer, or be a “specialist” in a particular area within the company (the work must then be critical to the entire company). To qualify as a “researcher,” the employee must have qualified research or development duties with such a focus or level of competence that it entails significant difficulties to recruit within Sweden. The research must be independent and have been conducted at a certain level for at least 1–2 years after the PhD.
What other formal requirements must be met?
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The employee may not be a Swedish citizen.
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The employee must not have lived in or had their habitual residence in Sweden at any time during the five calendar years preceding the year in which work in Sweden begins.
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At the time of application, the intention must be that the employee’s stay in Sweden will last no more than seven years.
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The employer must be resident in Sweden or be a foreign company with a permanent establishment in Sweden.
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The application must reach the Taxation of Research Workers Board no later than three months after work in Sweden has commenced. The application may be submitted by either the employer or the employee.
The expert tax relief means that:
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25 percent of cash remuneration and benefits is exempt from taxation and from the basis for Swedish employer social security contributions.
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Costs borne by the employer for school fees for children’s education in primary school, upper secondary school, or equivalent are fully tax-free.
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Costs borne by the employer for two trips home per year for the employee and the family are fully tax-free.
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Costs borne by the employer for moving to and from Sweden are fully tax-free.
The tax relief applies for a maximum of seven years from the employee’s first day of presence in Sweden.
What changes are proposed regarding the expert tax relief?
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The expert tax relief is to be increased from the current 25 to 30 percent, meaning that 30 percent of salary and benefits will be exempt from taxation and from the basis for Swedish employer social security contributions.
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For those applying under the competence rule, it will no longer be required to demonstrate that there are significant difficulties in recruiting individuals with equivalent competence in Sweden.
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For those applying under the threshold rule, the proposal is to use the income base amount as reference The required remuneration level shall correspond to one income base amount for the year in which the work commences (for 2026, the income base amount is SEK 83,400). Currently, the price base amount is used, and the required remuneration level is that the salary exceeds 1.5 price base amounts. For 2026 the minimum is SEK 88,801 as the price base amount for 2026 is SEK 59,200.
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The requirements that the employee must not be a Swedish citizen and that the intended stay in Sweden must be no longer than seven years will be abolished. However, the requirement that the employee must not have resided in Sweden before commencing work will be extended from five to seven years.
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A lifetime cap of 84 months (7 years) of application per person under the expert tax rules will be introduced, but the seven-year period may be divided across multiple periods of work in Sweden. An individual will no longer be able to have repeated seven-year periods with expert tax relief in Sweden.
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The application period for expert tax relief will be extended from three to six months after the employee has commenced work in Sweden.
Our comments
We view the proposal very positively. It becomes more attractive for both the individual and the employer when 30 percent rather than 25 percent of salary is exempt from taxation and the basis for social security contributions. The increased flexibility means that work can be spread across multiple periods, making it possible to also recruit individuals who have previously worked in Sweden but have not exhausted the full seven-year period. Finally, the requirement that the individual must intend to stay in Sweden for no more than seven years is being removed. This has been a requirement that has been difficult to prove, both for applicants and authorities, and has created uncertainty. Furthermore, individuals who intend to settle permanently in Sweden will no longer be disqualified from receiving expert tax relief.
The extended application period may not affect many people, but in situations where it was assessed that the individual would not become subject to unlimited tax liability in Sweden — but later turns out to be so due to an extension or a changed pattern of stay — it is a welcome change. This is because the application period has usually expired by the time it is discovered that the individual has become subject to unlimited tax liability in Sweden.
At PwC, we have specialists who can assist with everything related to the expert tax relief, for example assessing whether the requirements are met and preparing the application.
Read the press release (in Swedish) and the Council on Legislation referral (in Swedish) on the Government's website.
