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Delphi Tax Alert
The Swedish government has proposed new legislation which will entail further restrictions regarding tax deductions for interest expenses on inter-company loans. Kindly note that the proposed legislation will broaden the definition of the term ”affiliated companies”.
Simplified expert tax
The purpose of the rules when they were introduced was to strengthen Sweden’s international competitiveness and to create incentives for companies to choose Sweden for start-ups and encourage companies to locate or retain leading management functions in Sweden.
Temporary law on tax respite: postponing or preventing bankruptcies?
The rate at which corporate bankruptcies occur depends on a variety of factors. In Sweden, one of these factors may be the temporary law on tax respite. The tax payments that were delayed fall due on January 17 2011.
Sale of subsidiary and deduction for input VAT on consultancy costs
The Administrative Court of Appeal in the so-called SKF case refused a deduction for input VAT on certain consultancy costs incurred in conjunction with disposal of a subsidiary. The case is particularly interesting for companies which procure services in conjunction with so-called packaging of properties and for advisors in such transactions. Delphi’s tax advisors Mikael Knutsson and Johan Kristoffersson report on case law.
Worse tax position for R&D in Sweden
An article in Biotech Sweden in August 2010, which is based on material supplied by Peter Utterström at Delphi, concludes that Swedish tax rules for R&D companies are more restrictive than those which apply in several other EU countries.
Sale of Subsidiary and Deduction for Input VAT on Consultancy Costs
The Administrative Court of Appeal in the so-called SKF case refused a deduction for input VAT on certain consultancy costs incurred in conjunction with disposal of a subsidiary. The case is particularly interesting for companies which procure services in conjunction with so-called “enveloping of properties” and for advisors in such transactions.
Taxation of gift of future dividend
Two new Supreme Administrative Court rulings make it clear that it is possible to give away dividends from a closely-held company without the giver being taxed for the dividend.
Time of employee’s acquisition of shares with restricted right of disposal
The time of acquisition is decisive in terms of when taxation takes place. Oscar Nilsson reports on two rulings from the Supreme Administrative Court.
Agreement on the exchange of information between countries in taxation matters
Sweden has entered into new agreements with several countries on the exchange of information in taxation matters. Thomas Håkansson reports on the new agreements.
Proposals to Limit Interest Deductions
Government proposes change in limitations regarding interest deduction for internally financed acquisition of shares (etc.) in a privity (unity of interests).
Proposal to amendments of the tax legislation on account of the 2008 finance bill
Ahead of the Autumn finance bill, the goverment has stated that SEK 30billion will be designed for reforms in the labour market and enterprise, welfare and investment for the future
Treaty Override - a Tax Treaty's relation to (new) Swedish CFC rules
On 3 April 2008, the Supreme Administritive Court announced a decision in a case which has given rise to strong reactions amoung tax law specialists.