On November 7, 2016 a government committee which was appointed in May 2015, presented its report “Tax on financial services” to the government. The committee was appointed under the assumption that the financial services sector, in comparison to other sectors, has a tax advantage due to financial services being exempt from VAT. The committee proposes a financial activity tax of 15% to be introduced.

Companies Subject to the Tax

Entities supplying VAT exempt services under Chapter 3, Article 9 – 10 in the Swedish VAT Act, which are also liable to pay social security contributions in Sweden, are suggested to be covered by the financial activity tax. Entities that are acquiring VAT exempt services from abroad will also be in scope of the tax. The report does not suggest any minimum thresholds.

Given the above, the report implies that the financial activity tax will be given a broad application as it potentially covers any company producing VAT exempt financial services or acquiring VAT exempt financial services from abroad. In addition to banks, insurance companies, fund companies, and similar providers of financial services, companies with treasury functions, intermediaries of financial services as well as IT-companies providing financial services may be included.

Governmental bodies will be subject to the tax with the exception of the Swedish central bank. 

Taxable basis

The tax is proposed to be set at 15%, designed as a form of additional salary tax as the tax base will comprise the total salary costs during a tax year.

Coming into Force

The new tax is suggested to enter into force as of 1 January 2018.

KPMG Comments

The committee’s proposal follows the instructions it was given and presents many similarities to the Danish activity tax (sw: "lönsumsavgift") in force since the 1990’s. The proposal has been subject to discussions and debates in the Swedish media prior to the offficial announcement. We note specifically that not only companies under the supervision of the Swedish Financial Supervisory Authority will be in scope of the proposed financial activity tax, and also that the proposal does not contain thresholds – basically including companies providing only a single VAT exempt service. As such, it is crucial for all concerned companies to consider the impact of the proposal if implemented.

Furthermore, we note that the report contains a number of dissenting opinions from experts involved. We are currently analyzing the proposal and the dissenting opinions.

As a next step in the legislative process, the proposal will likely be circulated for formal consultation. Other parties than appointed consultation bodies may provide its views on the proposal.
 

You are welcome to contact us for discussions or should you have any queries on what the proposal may mean for your business.