English TaxNews

English TaxNews

A newsletter with the latest news in Swedish and international tax law and related areas. The subscription for KPMG TaxNews is free and the newsletter is issued as soon as there are interesting news in the area.

1000

Contact

Annika Lindström

Partner & Head of Tax & Legal

KPMG i Sverige

E-post
TaxNews-dekorbild

2023-2024

Court confirms: Audi AG does not have a permanent establishment in Sweden
KPMG has acted as counsel in a case regarding permanent establishment as a result of winter testing activities. (2024-12-04)

Swedish parliament adopts amendments to the Øresund treaty
The changes are intended to facilitate cross-border commuting between Sweden and Denmark. (2024-11-28)

KPMG represented client in landmark tax-case in the Supreme Administrative Court
The court offers welcome clarification on claims for corresponding adjustments. (2024-11-25)

Portuguese withholding tax on services
Opportunity for Swedish companies to recover a full or partial refund of the withholding tax imposed on Portuguese-sourced income. (2024-11-19)

CJEU: VAT on E-mobility business models
The case holds significant implications for a wide range of service providers within the automotive sector. (2024-10-29)

CJEU: Swedish withholding tax on dividends to foreign public pension institutions is contrary to EU law
The Swedish regulations violate the free movement of capital. (2024-07-30)

Improved interest deduction rules for companies?
The proposal represents a new system for calculating a group's maximum interest deduction. (2024-06-13)

Pilot service for digital passport control
The Swedish Migration Agency is launching a pilot service at the end of May 2024.(2024-05-17)

Proposed changes to the remuneration rate level for expert tax relief
The Swedish government proposes a lower threshold for expert tax. (2024-04-24)

Stricter rules for labor immigration
The proposals in the investigation are proposed to come into force from 1 June 2025. (2024-02-16)

Update on Swedish permanent residence requirements
Judgement from the Swedish Migration Court of Appeal clarifies the interpretation of the “certain duration” requirement for permanent residency. (2024-01-19)

VAT recovery on the disposal of shares in a subsidiary undertaking
KPMG has acted as the representative in the case before the Supreme Administrative Court in Sweden. (2023-11-02)

Swedish VAT pro-rata rules is in violation of EU law
KPMG has acted as representative in a case in the Supreme Administrative Court. (2023-10-19)

Tax withholding rules targeting foreign contractors deemed to breach EU law
The Swedish government has responded to the EU Commission’s formal notice. (2023-09-28)

Increased income requirement for work permit applications
The regulation will enter into force on 1st of November without any provisional regulations. (2023-09-25)

A new work permit application process
The introduction of the new process is planned for the end of 2023. (2023-05-17)

2022

Increased price base amount raises threshold for Swedish expert tax 
Higher salaries required to qualify for expert tax based on compensation in 2023. (2022-09-06)

Revised proposal for amended legislation on withholding tax on dividends 
The proposal would effect both foreign recipients of dividends and Swedish companies. (2022-06-20)

Employees Working from Home: New Legal Guidance Issued on PE Risks
The Swedish Tax Agency issues statement on when a permanent establishment may arise. (2022-05-20)

KPMG releases new tool for streamlined VAT Validation
KPMG’s VAT Validator enables companies to validate hundreds of VAT numbers in just one click. (2022-04-06)

Foreign companies’ filing requirements including “specific information"
On 1 January 2021, the Swedish Tax Agency introduced new rules regarding "specific information" (Sw. särskilda uppgifter). (2022-03-02)

2021

The Swedish Supreme Administrative Court clarifies Swedish "expert tax" rules
How compensation paid to foreign workers is to be calculated in order to assess whether the employee may be entitled to so-called expert tax. (2021-12-20)

Agreement on social security between Sweden and Japan
On 27 October 2021, the Swedish Parliament decided to vote in favor of an agreement on social security between Sweden and Japan. (2021-11-26)

New proposal from the European Council to harmonize regulations for EU blue card
The aim is to facilitate circular migration. (2021-11-11)

The Budget Bill 2022 from an immigration perspective
According to the Swedish government, the Swedish Migration Agency’s focus should be to streamline processes and improve digitalization. (2021-09-30)

A new Withholding Tax Act
The Swedish government intends to implement a new Withholding Tax Act, to be applied in respect of dividends paid after December 31st, 2023. (2021-09-27)

Change in regulations regarding permanent residence permits in Sweden
Since 20 July 2021 updated regulations has come into force regarding applications for permanent residence permits. (2021-09-14)

The Supreme Administrative Court decides the Lexel case on the Swedish interest deduction limitation rules 
The Swedish SAC concludes that the interest expenses should be deductible for the company. (2021-03-22)

CJEU: The Swedish interest deduction limitation rules are in breach of EU law
The Court of Justice of the European Union (CJEU) published a preliminary ruling in the Lexel case (C-484/19) in which the court finds that the exception to the ten percent rule in the 2013-2018 Swedish interest deduction limitation rules is contrary to the freedom of establishment. (2021-01-20)

2020

New rules on tax withholding for work in Sweden and obligation to file specific information 
From 1 January 2021 the rules on tax withholding for work performed in Sweden will change, resulting in more foreign companies needing to register at the Swedish Tax Agency. Additionally, foreign companies that are registered for F-tax but do not file a tax return must provide specific information (särskilda uppgifter) each year. (2020-12-08)

The Swedish Parliament has approved the introduction of the economic employer concept in Sweden 
The new regulations will be effective as of 1 January 2021. (2020-11-04)

New expert tax relief rules coming up in Sweden? 
The Swedish Ministry of Finance proposes changes to the tax relief for foreign experts, scientists and other key personnel staying temporarily in Sweden (expert tax relief). (2020-08-26)

Increased employment rights and compliance requirements for posted workers into Sweden 
As of July 30, 2020, the employment rights for posted workers to Sweden will be more comprehensive. (2020-07-03)

New Proposal on the Economic Employer Concept
On 23 June, the Swedish Government once again published a proposal to implement the economic employer concept in Sweden. The Government intend to implement the new regulations 1 January 2021. (2020-06-25)

KPMG Sweden wins 5th consecutive National Tax Firm of the Year award – Tina Zetterlund recognized for her leadership 
KPMG Sweden got to celebrate twice in the European Tax Awards. For the fifth consecutive year, KPMG was named National Tax Firm of the Year, and Tina Zetterlund won the award as EMEA Tax Practice Leader of the year. (2020-05-27)

Proposal for a new law on withholding tax on dividends
With this proposal the Ministry of Finance hopes to achieve an efficient and modern regulatory framework. (2020-05-05)

Swedish Tax Agency adopts the OECD principles on financial transactions, changing long-standing guidance
The Swedish Tax Agency has updated its guidance on the pricing of financial transactions. (2020-05-05)

Recent case law has implications for MNE groups acquiring Swedish companies with significant intellectual property 
The case law illustrates that ownership of intangibles may change following a third-party acquisition. (2020-04-22)

The Swedish Chemical Tax on electronical products and white goods is proposed to be expanded 
A new government bill proposes that the Chemical Tax on electronical products and white goods shall be expanded to include B2C transactions from foreign companies as from October 1, 2020. (2020-04-20)

Extra working days from home in Sweden due to COVID-19 will not alter social insurance cover in the EU
The Swedish Social Insurance Agency has announced that additional working days from home in Sweden due to COVID-19 will not affect multi-state employees’ social insurance cover in the EU. (2020-03-19)

The new tax on plastic bags
On 1 March 2020, a new tax on plastic bags came into force in Sweden. However, the actual tax liability will be due from 1 May 2020. For those who has not already begun their work of planning for the new tax, now is the time. (2020-03-04)

Swedish SAC: A foreign investment fund’s legal form does not prevent it from using dividend WHT exemption
The ruling confirms that legal form does not prevent foreign investment funds from being comparable to Swedish investment funds. (2020-02-27)

OECD releases the final Transfer Pricing Guidance on Financial Transactions
The report aims to provide guidance on financial transactions that have been a frequent source of disagreement between tax agencies and taxpayers. (2020-02-13)

The Swedish government wants to attract international competence and counteract exploitation of labor immigrants
The Swedish government has appointed a committee to analyze and propose actions to attract international competence and counteract exploitation of labor immigrants. (2020-02-11)

Increased relief on social security for research and development (R&D-relief) from 1 April 2020 
Proposed bill on adjusted rules for R&D has been submitted to the Swedish Parliament. (2020-01-23)

2019

The Swedish Supreme Administrative Court: Director’s fees to be treated as income from employment 
The Swedish Supreme Court has published a new ruling about director's fees. (2019-12-17)

Supply between VAT group and branch, new referral to ECJ from Sweden 
The Swedish Supreme Administrative court (SAC) today 30th October announced its decision to request a preliminary ruling from the Court of Justice of the European Union (EUCJ) regarding the VAT treatment of supplies from an overseas head office to its branch in Sweden, where the overseas head office only is a member of a VAT group. (2019-10-30)

The Swedish government plans to introduce stricter taxation for Business Travelers and posted workers in Sweden
As from 1 January 2021 the Swedish government plans to introduce stricter taxation for Business Travelers and posted workers in Sweden. (2019-09-09)

Swedish Supreme Administrative Court confirms tax ruling on withholding tax and yield tax
Swedish Supreme Administrative Court confirms tax ruling on withholding tax and yield tax in relation to foreign life insurance. (2019-06-26)

Mandatory Disclosure Reporting coming up 
Mandatory Disclosure Reporting coming up - with some effects as of June 25, 2018. (2019-02-15)

New reporting system – employer return on an individual basis
As of 1 January 2019 every employer that is required to file a monthly employer tax return must now report the information both on an individual level and on a company level. (2019-01-17)

New Swedish Gambling Tax Enters into Force with Limited Time for Compliance
There are some potential challenges that may occur due to when and how this tax should be reported. (2019-01-11)

2018

No implementation of the suggested rules for temporary work in Sweden by 1 January 2019 
The introduction of ‘economic employer’ in Sweden is postponed. (2018-09-21)

Extended CFC legislation proposed
The purpose of the proposal is to make various kinds of tax planning involving companies in foreign jurisdictions more difficult. (2018-09-11)

Supplementary proposals regarding taxation and payment of tax for temporary work in Sweden
The Swedish government adjusts its proposal regarding the so-called hiring out of labor rule. (2018-08-16) 

OECD releases discussion draft on the transfer pricing aspects of financial transactions
OECD has issued a Public Discussion Draft on Financial Transactions, as part of its continuing work on Base Erosion and Profit Shifting (BEPS). (2018-07-06)

New legislation on the limitation of interest deductions and corporate tax rate cut
The Swedish Parliament passed 14 June a bill with the enactment into Swedish law of the EU Anti-Tax Avoidance Directive. The new rules include new interest deductions rules that will have substantial impact for a large number of companies in Sweden. Moreover, the corporate tax rate will be lowered din two steps. Please see our previous TaxNews for more information. (2018-06-15)

The Swedish Government wants to apply the economic employer concept in Sweden from 2019  
If the proposal becomes legislation, this would result in extended tax liabilities and reporting requirements for foreign employer and employees. (2018-05-24)  

Swedish Government proposes new interest deduction limitation rules and corporate tax cuts
The Swedish Government has now presented its proposal on new tax legislation re interest deduction in the corporate sector. (2018-03-23)

Swedish Administrative Court of Appeal ruling about transfer pricing
The Administrative Court of Appeal in Stockholm has reached a decision concerning questions related to the timing of data and information in a Benchmarking search that can be used to test whether the price is set at arm-length. (2018-01-23)

2017

Tax changes in the Swedish Budget Bill for 2018
The Budget Bill for 2018 was presented to the Swedish parliament (Riksdagen) last week. (2017-09-26)

Proposal on a revised definition of the employer concept
If the proposal becomes legislation, this would result in extended tax liabilities and reporting requirements for foreign employer and employees. (2017-06-30)

The Swedish Supreme Administrative Court: Director’s fees are usually income from employment
A decision of the high court in Sweden provides that certain fees paid to company directors are taxable as income from employment. (2017-06-27)

Government memorandum proposing corporate tax cuts and new interest deduction limitation rules
A Government memorandum proposing corporate tax cuts and new interest deduction limitation rules has been released today. (2017-06-20)

Proposal for amended Swedish tax legislation for real property transactions
On March 30, the special appointed Committee presented its proposal for amended Swedish tax legislation for real property transactions. (2017-04-11)

Proposal for new regulations of gambling in Sweden
Today, a proposal for new regulations of gambling in Sweden was presented to the government. (2017-03-31)

New legislation on Transfer Pricing Documentation and CbC
On March 1 the parliament passed the Government's proposal for Transfer Pricing Documentation and Country-by-Country Reporting. The regulations will enter into force on April 1, 2017. (2017-03-03)

Withdrawal of the proposal on a Financial Activity Tax in Sweden
Late Friday the 24th of February, the Swedish government announced that it will not proceed with the proposal on a Financial Activity Tax. (2017-02-27)

New ruling regarding the possibility to invoice director’s fees from a private limited company
In a decision that went against the Swedish Tax Authority’s current public guidance (issued in 2008), on the 21 December 2016 the Council for Advance Tax Rulings upheld that earlier more restrictive precedence from 1993 is applicable in determining whether a director’s fees may be invoiced from a private limited company. This decision means that the current legal position is unclear. (2017-02-01)

2016

Proposal on a Financial Activity Tax in Sweden
On November 7, 2016 a government committee presented its report “Tax on financial services” to the government. (2016-11-08)

Creation of Permanent Establishment due to reoccurring short-term activities in Sweden
A Swedish Administrative Court of Appeal has issued a decision in a case regarding Permanent Establishments. (2016-11-07)

The Swedish Tax Agency proposes measures linking tax policies and sustainability
The Swedish Tax Agency proposes tax policy requirements for state-owned companies and confirms tax as a sustainability issue. (2016-11-07)

Swedish judgment on the arm's length principle and the Swedish Tax Agency’s comment
Section 14 paragraph 19 Income Tax Act (ITA) can be applied when an agreement with certain contractual terms and conditions is replaced by another agreement with not as beneficial terms and conditions, although they by themselves are considered to be at arm's length, according to the Supreme Administrative Court (SAC). (2016-07-06)

© 2024 KPMG AB, a Swedish Aktiebolag and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

 

For more detail about the structure of the KPMG global organization please visit https://kpmg.com/governance.

Kontakta oss

Spara, organisera och dela

Spara det som intresserar dig, organisera ditt bibliotek och dela i ditt nätverk.