On 23 February 2021, officials from Sweden and the UK signed an amending protocol to the 2015 income and capital tax treaty between the two countries. The protocol is the first to amend the treaty and includes the following main changes:
- The title and preamble are replaced in line with OECD BEPS standards;
- The specific main purpose tests limiting benefits of Articles 10 (Dividends), 11 (Interest), 12 (Royalties), and 20 (Other Income) are removed;
- Article 23 (Mutual Agreement Procedure) is u…