On 23 November 2005, Sweden ratified the new protocol to the Sweden-United States Income Tax Treaty of 1 September 1994, signed on 30 September 2005, by way of Law SFS 1994:1617 published in the Svensk Frfattningssamling (official publication of statutes in Sweden).

The protocol provides for a zero withholding tax in respect of inter-company dividends. The application of the zero rate essentially requires that (i) the beneficial owner is a company resident of the other contracting state that has owned, directly or indirectly, through one or more residents of either contracting states, shares representing 80% or more of the voting power in the company paying the dividends for at least a 12-month period ending on the date on which the entitlement to the divid…