UK HMRC has published a Memorandum of Understanding (MoU) between the competent authorities of the United Kingdom and Sweden to establish the mode of application of the arbitration process provided for in Article 23 of the 2015 income and capital tax treaty between the two countries, as amended by the 2021 protocol. Article 23 (Mutual Agreement Procedure) provides that if the competent authorities are unable to reach an agreement to resolve a case within two years from being presented to the…