Sweden: Proposed tax law changes related to new rules for cross-border divisions between EU member states
Proposed tax law changes would become effective 1 January 2024
New rules for cross-border divisions between EU member states
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.
The KPMG member firm in Sweden has prepared a series of three articles to discuss the new rules, focusing on:
- Cross-border conversions (read TaxNewsFlash)
- Cross-border mergers (read TaxNewsFlash)
- Cross-border sharing (read TaxNewsFlash)
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.
Read an April 2023 report (Swedish) prepared by the KPMG member firm in Sweden
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