Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, the information provided below cannot be considered as comprehensive or deemed to constitute specific legal advice.
Yes we tax in Sweden
New tax reform: No specific information
New tax treaties: No specific information
Local tax advisors
No specific information on the local tax advisors.
The definition of Permanent Establishment follows the wording of article 5 of the OECD Model:
- Dependent agent who habitually concludes contracts in the name of a non-resident company (except if the activity is limited to purchase of goods);
- Fixed place of business, building site, construction, assembly or installation and any related supervisory activity.
Resident companies are taxed on their worldwide income (« worldwide principle »). However, non-resident companies are only taxed on their revenues derived from Sweden sources (« source principle »).
Entities are considered to be resident for tax purposes in Sweden if their registered office is in Sweden or if their place of management & control is in Sweden.
Note: the definitions of permanent establishment and place of residence are subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 22%.
Non-taxable income includes the following:
- Dividends received from qualifying participations
- Certain capital gains deriving from qualifying participations
- Tax refunds
Non-deductible expenses includes the following:
- Dividends benefiting from the participation exemption
Carry forward: Yes indefinitely, but some restrictions may apply.
Carry back: No
Companies should submit the tax return annually before the 1st July of the following year.
Annual tax returns are established by the company on a self-assessment system.
Whithholding Taxes (payment to foreign companies)
The local tax rates in Sweden are the following, subject to the provisions of an applicable double tax treaty, if any.
There is no WHT on the profits paid from a branch to its foreign head office.
The general rate of WHT on dividends is 30% of the gross amount.
The general rate of WHT on interest is 0%.
The general rate of WHT on Royalties is 0%.
The general rate of WHT on management fees is 0%.
The general rate of WHT on technical services is 0%.
Generally, capital gains are taxed under the regular CIT as general income.
Note: capital gains deriving from qualifying participations are exempt under the participation exemption.
Standard VAT tax rate is 25%
Reduced tax rates are:
- 12% (among others, collector’s items and antiques; import of foodstuffs, restaurants, bikes, shoes, clothing…);
- 6% (among others, books, personal transport, museums, …)
Zero-rated supplies include, subject to certain conditions:
- exports of goods;
- International passenger transportation.
- intra-Community supplies of goods;
- Aircraft engaged in commercial international traffic;
- Services related to zero-rated vessels and Aircraft;
- transport of goods and services directly related to import and export of goods;
Exempt supplies include, subject to certain conditions:
- Certain financial services ;
- Certain insurance services ;
- Training and education ;
Note: exempt transactions differ from zero-rated transactions in that the input VAT associated with exempt transactions is not deductible.
EU taxable companies may claim a VAT refund to their own tax authorities through on the basis of the 13th EU Directive.
In case where for a tax period, Input VAT exceeds Output VAT, certain non-resident companies (which are not required to register and incur Sweden-VAT in the course of their business activities in Sweden) may apply for a refund under the same conditions than resident companies.
No other specific information of VAT in Sweden.
The general statute of limitation is 5 years starting at the end of the year in which the tax return had to be filed.
There is no foreign exchange control in Sweden. Income and capital could be freely repatriated.
There are no thin capitalization rules in Sweden
Do not hesitate to share your experience in Sweden with us in the comments below. Any comments are welcome !