In June 2026, KPMG published a TaxNews article on the Government's legislative proposal "Continuous Stay in Sweden – A Definition", which proposed introducing a statutory definition of continuous stay in the Swedish Income Tax Act. The Government has now submitted Government Bill 2025/26:306 to Parliament. The bill is, in all material respects, consistent with the proposal previously presented and would introduce a statutory, predominantly quantitative definition of continuous stay in Sweden.
Continuous stay in Sweden is one of the grounds for becoming unlimited tax liable in Sweden. A person who is considered to be in continuous stay in Sweden may therefore become subject to Swedish taxation on both Swedish and foreign-source income, subject to any limitations arising under an applicable tax treaty. As the Swedish Income Tax Act currently does not contain an explicit definition of the concept, the assessment is largely based on case law, which can make it difficult to predict whether a particular presence in Sweden will result in unlimited tax liability.
Under the bill, continuous stay would be determined based on the number of days spent in Sweden during a calendar year. As a main rule, continuous stay will be deemed to exist where an individual spends more than 160 days in Sweden during a calendar year. A supplementary rule provides that continuous stay will also be deemed to exist where an individual spends more than 120 days in Sweden during a calendar year, provided that the individual also spent more than 120 days in Sweden during the preceding year.
The proposed legislative amendments are scheduled to enter into force on 1 January 2027.
