Proposed changes to the remuneration rate level for expert tax relief

Since 2012 it is possible for an employee to be granted expert tax relief in Sweden based solely on the employee’s pay. Provided the remuneration exceeds a minimum income level, expert tax relief can be granted without any formal examination of the employee's skill or competence. The purpose of the income based threshold was to simplify the application process and increase the attractiveness to recruit specialists to Sweden.

The Swedish government now proposes that the threshold should be lowered. In a memorandum, the Ministry of Finance brings forward the possibility of lowering the minimum income level in order to be granted expert tax relief based on remuneration. The new regulations are proposed to enter into force on 1 January 2025. The proposal means that the level for being granted expert tax is lowered from two price base amounts (SEK 114,601) to one and a half price base amounts (SEK 88,500). 

The level of the current minimum level was introduced in relation to an average annual salary for the group that was granted expert tax at that time. The memorandum mentions other countries' levels of similar tax regulations that the expert tax entails. Among other things, levels in Belgium, Denmark and Finland are mentioned. The overall assessment is that the level in other comparable countries is lower than in Sweden and that revising the level in Sweden is therefore considered justified. Inflation is also raised as an argument for reviewing the income level. Furthermore, it is argued in the memorandum that Sweden is in strong need of being competitive in an international labor market. A revision of the regulations and a lowering of the amount limit are considered to have positive effects for employers to, among other things, offer competitive salaries and retain employees in group-leading positions. As a consequence of a lower amount limit, the memorandum also mentions that people who currently meet the requirement to be granted expert tax on the qualification requirement can instead utilize a quicker turnaround time if they are covered by the income requirement. According to the Swedish Tax Agency, approximately 3,900 people are granted expert tax (2023). 

In order to further develop the regulation concerning expert tax, the government has also appointed a special investigator to present further proposals in the area. Among other things, under investigation is also whether the competence rule should be clarified or completely removed in favor of an income level. Since the salary levels can also shift between different professional groups, the investigator should also look at this to develop proposals that may result in the income level being further lowered within certain groups. 

• Employers can review any plans to recruit as the new regulatory framework is proposed to come into force on 1 January 2025. There may be value in planning start dates in a pragmatic way to ensure that employees can be covered by an updated regulatory framework. 
• It is an important step in strengthening Sweden as a knowledge nation and goes in an overall direction in investing in attracting highly qualified labor to Sweden.
• We already see today that many key people who apply for expert tax based on the knowledge criteria and do not reach the income level are often affected by lengthy processing and a more unpredictable assessment. KPMG sees this as a positive development as the income level as the income level route is predictable and clear.

KPMG is following the development of this proposal and the ongoing investigation and will return with updates. You are welcome to contact us to discuss how the proposal affects you.

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Örjan Berg
Auktoriserad skatterådgivare
KPMG i Sverige
+46 76 877 12 28
orjan.berg@kpmg.se