Sweden Tax News
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Bill to implement 2005 amendments to EC Merger Directive adopted
Protocol to treaty between Sweden and Austria approved
Amendments to implement 2005 amendments to EC Merger Directive
Swedish proposal to approve amending protocol to Sweden–Austria treaty submitted to parliament
Budget for 2007 – details
Protocol to treaty between Sweden and Austria signed
Protocol amending treaty between US and Sweden enters into force
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
European Commission requests Belgium to terminate discriminatory taxation of inbound dividends
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
Proposal to terminate tax treaty between Sweden and Peru adopted
Treaty between Peru and Sweden – negotiations
Proposal to clarify rules on set-off of capital losses on unquoted and quoted participations
Proposal to terminate treaty between Sweden and Peru submitted
US Senate ratifies protocol to treaty between Sweden and US
US Foreign Relations Committee approves protocol to treaty between Sweden and US
Rules to prevent tax evasion proposed
US Senate hearings on protocol to treaty between Sweden and US
Amendments to Income Tax Law and Coupon Tax Law
The first-time income tax treaty and protocol between Chile and Sweden, signed on 4 June 2004, entered into force on 30 December 2005. The treaty generally applies from 1 January 2006.
Amendments on taxation of owners of small and medium-size enterprises
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).
Details of the protocol signed by Sweden and the United States on 30 September 2005 to the Sweden-United States income tax treaty of 1 September 1994 have become available. 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 dividends is determined and (ii) certain conditions under the tax treaty's limitation-on-benefits clause are met. Under certain conditions, pension funds are also eligible for the zero rate.
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