The Ministry of Finance released a memorandum proposing tax law changes related to the new rules for cross-border divisions, conversions and mergers between EU member states which became effective 31 January 2023.
KPMG Sweden has published a series of three articles to discuss the new rules, focusing on:
The proposed tax law changes, which would become effective 1 January 2024, include:
Deferment of withdrawal tax over a five-year period for companies that move their headquarters from Sweden to another EU country through cross-border conversion
Conversely, application of the rules on acquisition value and acquisition cost at the time of taxation to companies that move their headquarters to Sweden from another EU country through cross-border conversion
Amendment of the existing rules on business divestments to clarify that they may apply to divisions through cross-border sharing and, as with cross-border conversions, deferment of any associated withdrawal tax
The government has requested comments on the proposed changes until 17 May 2023.
