Tax in Sweden

Mannheimer Swartling

In tax litigation, Mannheimer Swartling’s group head Anders Erasmie is involved in a number of the prominent cases in the market involving the imposition of corporate tax penalties and VAT exemptions. The team also has a full-service transactional tax practice, with Niklas Hagbard advising private equity funds and corporate clients on tax structuring issues arising from M&A transactions, IPOs, corporate expansions, restructurings, incentive programmes and co-investments. The firm also fields a dedicated team advising on fund formations, fund exits and tax and asset managements; Martin Nilsson is a go-to name in the group.

Practice head(s):

Anders Erasmie

Testimonials

The team is responsive, to the point and solutions oriented.

The tax team is highly competent, easy to work with and commercial.

A highly technical and very practical approach.  Very good command of the latest tax practices.  Best in class for Swedish tax matters.

Martin Nilsson provides honest and straightforward communication.

Anders Erasmie and Martin Nilsson are responsive, to the point and solutions oriented.

Anders Erasmie is dedicated, very responsive, pleasant to deal with, creative and very knowledgeable. He is a sharp advocate with great litigation qualities.

Key clients

Swedish Match

Nordic Capital

Uniper

Cevian

Ratos

E.ON

Flir

Accent

Work highlights

  • Representing insurance broker Marsh in VAT litigation against the Swedish Tax Agency.
  • Representing private equity fund Nordic Capital in tax litigation concerning the ‘closely held profits’ principle on repatriated profits.
  • Providing tax advice on the closure of Fairpoint Capital’s SEK900m fund.

Advokatfirman Vinge

Advokatfirman Vinge has particular expertise in tax structuring work, with practice head Mattias Schömer advising market-leading private equity houses on the formation of debt and equity funds. The firm also fields dedicated partners in tax litigation and M&A support, with Maria Schultzberg, Thomas Andersson and Ulrika Bengstsson receiving domestic and cross-border mandates. Recent contentious issues included acting in disputes relating to tax rates and handling transfer pricing claims for corporate clients in the financial services sector. Ulf Nilsson is the team’s VAT expert.

Practice head(s):

Mattias Schömer

Key clients

Oriflame Holding A.G.

Internationella Engelska Skolan Holdings II AB

R12 Kapital i Stockholm

Calliditas Therapeutics AB

Fidelity Investments

Nuevolution AB

Tele2 AB

Altor

Valedo AB

Segulah

Work highlights

  • Advising on the tax structuring elements of the establishment of Capillar, a Swedish private equity fund.
  • Representing Björn Savén in tax litigation concerning a SEK1.5bn tax reassessment.
  • Representing Adelis Equity Partners Fund I in tax litigation concerning a significant reassessment by the Swedish Tax Agency.

Bird & Bird

Leading Bird & Bird’s tax practice, Carl-Magnus Uggla is a key name for real estate tax issues and is routinely instructed by international real estate funds to provide tax structuring advice and due diligence on pan-Nordic transactions including complex forward funding structures. The team also advises insurance firms, media clients, public bodies, high-net-worth individuals and financial institutions on remuneration planning work, SPA negotiations and cross-border tax restructuring issues. Uggla also provides advice on investigations by the Swedish Tax Agency.

Practice head(s):

Carl-Magnus Uggla

Key clients

Accountor AB

AF Gruppen

AirBnB

Ålandsbanken

ARM

Barings

Boliden

Citi Group

Consensum Produktion AB

Delivery Hero

Deutsche Bank UK

Etraveli

Hiscox

HSB Projektpartner

Lateral Management

Live Nation

Mattsson Fastighetsutveckling AB

NorthStream AB

Oivor AB

Scandic

Shellback Industries

Tempur Sealy

Work highlights

  • Provided tax structuring and sell-side tax advice to Northstream on its share sale to Accenture.
  • Provided a cross-border tax assessment to real estate fund AREIM for its investment into Chinese real estate fund White Peak.
  • Provided tax structuring and due diligence advice to asset management firm Barings for its forward funding real estate acquisition.

DLA Piper

DLA Piper’s tax team advises on domestic tax issues as well as cross-border mandates through the firm’s international network. Practice head Erik Björkeson and senior associate Magnus Hagevi routinely provide tax advice on large-scale corporate transactions and company restructurings, particularly in the private equity, real estate and life sciences sectors. On the contentious side, the team is handling litigation relating to interest deduction rules and tax reassessments by the Swedish Tax Agency; senior counsel Fredrik Gustafsson is a go-to name for the latter.

Practice head(s):

Erik Björkeson

Testimonials

Magnus Hagevi is solutions oriented with his advice. Most importantly, we trust that he has the knowledge to support and help us as a company.

Key clients

Svenska S Holding 2 AB and CVC

Aktiebolaget Electrolux

JPMorgan

Tec Ex

Avia Pharma

Green Park

Blue

Kaupthing Sverige

Euclid Transactional UK

AIG Property Casualty

URBASER SA

Access Capital Partners

RebTel Networks

Shape Technologies

Masimo Sweden

Svenska Blount Aktiebolag

Lombard North Central

Konica Minolta Sensing Europe B.V., the Netherlands, Nordic FIL

Nordic Mezzanine Fund

Åre 2019

Work highlights

  • Representing Svenska S Holding 2 in a €16m tax dispute concerning Swedish interest deduction rules.
  • Advising Aktiebolaget Electrolux on Swedish tax issues including interest deduction rules pertaining to the client’s US restructuring.
  • Advising Avia Pharma on the tax considerations for a company restructuring.

Setterwalls

Particular fields of expertise for Setterwalls’ tax practice include advising on real estate M&A issues, capitalisation and incentive programmes for start-ups, corporate restructuring work and IPOs. The group is jointly led by Sören Brekell and Niclas Hermansson in Malmö and Gothenburg-based Christian Sjöqvist. Recent contentious mandates include Brekell handling VAT litigation relating to the sale of goods in the EU and disputed cross-border tax exemptions. The client roster comprises domestic and international corporate names.

Practice head(s):

Sören Brekell; Niclas Hermansson; Christian Sjökvist

Key clients

Strabag SE

True Software Scandinavia AB

AFA Insurance AB

Boozt AB

Arise Windpower AB

TB Gruppen AB

Work highlights

  • Assisted True Software Scandinavia with the tax issues arising from its acquisition of the Indian fintech company Backwater Technologies.
  • Advised TB Gruppen on the tax issues concerning a joint venture with Fabege for a real estate development project.

Wistrand

Wistrand fields a highly regarded team of tax professionals including Rickard Jonason, Victor Palm and practice co-heads Conny Otteland and Peter Brandt. The team handles cross-border matters concerning transfer pricing issues, structuring advice for corporate transactions, fund formations, incentive programmes and real estate joint ventures. Notable contentious experience includes handling administrative appeals to tax decisions and tax audits, as well as advising on investigations by tax authorities; the practice represents businesses as well as high-profile individuals. Clients originate from a broad range of sectors including the financial services, insurance, IT and manufacturing industries.

Practice head(s):

Conny Otteland; Peter Brandt

Testimonials

A unique combination of skills in both tax and transactions within the real estate market.

The team understands very well our company, business and the environment we are active in. They are solutions oriented and very good at finding possible ways to handle both challenges and difficulties. They have skills in the tax area that are at the highest level compared to other firms.

The team has outstanding experience in Swedish tax law and practice, in particular with international taxation. The team covers all aspects of tax including litigation.

I have worked with the tax team in various client matters and it is the vast experience and thought-through tax advice which comes to mind. Given the size of the team, they are able to put forward the best tax lawyers for the specific job.

I have worked with Nils Sköld for 15 years in a great number of transactions and I have never been disappointed. He has also been an adviser to the board in different tax issues and that has been real helpful for our company’s growth. He has the ability to balance tax matters and business issues in a very professional way.

We are very satisfied working with Nils Sköld and Joakim Söderlund. They are both very competent in the tax area and are also very easy to work with. Their skills are at the very best you can find in the market.

Peter Brand is an excellent tax lawyer and litigator with broad experience in Swedish tax law.

Rickard Jonason has excellent client-handling skills and a broad international tax practice.

Christian Luthman is a real dealmaker; he simply solves the issues on the table one way or the other. His personal style and vast experience is certainly contributing to the success of the team.

Victor Palm is a thorough thinker, technically impressive and a nice person to work with.

Key clients

NIAM

Altro Invest AB

Soluno BC

Partners Group

Slättö Förvaltning AB

Einride

Work highlights

  • Assisted Niam with tax structuring issues and negotiations during fundraising for the Niam VII real estate fund.
  • Representing a construction company in multi jurisdictional tax litigation.

Baker McKenzie

Linnea Back heads up the tax practice at Baker McKenzie and is highly regarded for providing tax advice on M&A and capital markets transactions and company reorganisations. The team regularly advises on transfer pricing audits, employee incentive programmes and the VAT consequences of company restructurings. Back also has notable experience in tax litigation. Clients include global corporates, which are sourced from the firm’s international network.

Practice head(s):

Linnea Back

Work highlights

  • Provided tax advice on Mercury Engineering’s construction of data centres across Sweden.
  • Provided tax advice to the shareholders of Diamorph on the divestment of the company to Epiris Fund II.
  • Advised Polaris Private Equity Group and Jetpack Group on the tax issues arising from the latter’s IPO on Nasdaq First North.

Advokatfirman Lindahl KB

Advokatfirman Lindahl KB ’s tax professionals work closely with the corporate and M&A team to offer tax structuring advice on property acquisitions, joint ventures and corporate mergers. Highlights for Uppsala-based practice head Anna Romell Stenmark involved advising on cross-border company expansions and incentive schemes. Gothenburg-based Johan Myrén is another noted name with expertise in income tax and VAT issues. On the contentious side, the group also recently handled the interpretation of international tax treaties.

Practice head(s):

Anna Romell Stenmark

Key clients

MKB Fastighets AB

Koeningsegg Automotive

Olink Proteomics Holding AB

Work highlights

  • Provided tax advice to Koenigsegg Automotive on the formation of a strategic partnership with National Electric Vehicle Sweden.
  • Provided tax advice on MKB Fastighets’ real estate acquisition of Jägersro Trav- & Galopp Bana.
  • Advised Olink Proteomics Holdings on the tax issues arising from its sale to Summa Equity.

Linklaters

Linklaters’ tax practice head Ebba Perman Borg routinely assists with significant international M&A transactions, IPOs and fund-structuring mandates, typically for household names in the financial services, automotive, FMCG and private equity sectors. The team also advises on the tax structuring elements of global incentive plans and real estate transactions. Perman Borg also provides regulatory expertise pertaining to EU regulations, limitation rules and general legislative developments.

Practice head(s):

Ebba Perman Borg

Testimonials

Linklaters is always one of our first choices in the market. They have the ability to handle complex issues with simplicity and in a professional manner. Their tax practice is outstanding.

The Linklaters tax team is a highly experienced team focused on international tax structuring and tax aspects of M&A transactions, with a particular focus on private equity and the banking sector. Within these fields they are extremely capable and manage to build on a strong international network.

Experts in tax legislation.

Ebba Perman Borg’s advice is always pragmatic and user friendly.

‘Ebba Perman Borg has a solid combination of experience with handling cross-border matters, deep technical tax competencies and project management skills. She is a strong team member to have on-board, in particular for transaction-related and cross-border tax matters.

Ebba Perman Borg is very professional and she also has deep knowledge of our company.

Key clients

Unilever

Crédit Agricole S.A.

Triton

ASSA ABLOY

Volkswagen AG

Euroclear plc

IREEF Lux HoldCo 3 Sarl

KKR

Starwood Capital Group

Work highlights

  • Provided tax advice to Volkswagen as selling shareholder and Traton as issuer on the €1.6bn IPO of Traton.
  • Advising on Triton’s acquisition of SKF Motion Technologies from SKF Group.
  • Providing tax advice to Unilever on its disposal of an air purification business to third-party investors.

Magnusson Advokatbyrå

Magnusson Advokatbyrå’s tax practice provides tax structuring advice on company restructurings, M&A transactions, real estate investments, incentive programmes and capital markets transactions. Practice head Eric Cederström and Peter Wiker recently handled several contentious tax issues relating to cross-border staff operations and acquisitions in the energy sector. The team also lends its expertise to significant international fund formation mandates. The client list includes credit funds, real estate companies, energy companies and corporate entities.

Practice head(s):

Eric Cederström

Testimonials

Great commitment and engagement from professionals who provide personalised care.

Key clients

Söderberg & Partners

Pareto Securities

Pareto Alternative Investments

Intersolia Ltd

Nordic Credit Partners

Kognity AB

Fastighetsmäklarsamfundet FMF AB

Scandinavian Credit Fund

Cellar Capital Invest AB

CBC Investment Group

Erik Olsson Fastighetsförmedling AB

Lanterna Holding AB

HELFO, Helsedirektoratet

Qapital Inc

Mercer Global Investments

Work highlights

  • Handling the tax structuring for Pareto Alternative Investments’ establishment of a real estate fund.
  • Handled the tax structuring for the selling shareholders on the sale of a stake in Söderberg & Partners to KKR.
  • Representing the Norwegian Directorate of Health in a dispute with the Swedish tax authorities concerning healthcare personnel working between Sweden and Norway.

MAQS Advokatbyrå

Lars Odinge and Krister Hjelmstedt, based in Gothenburg and Malmö respectively, are key contacts in MAQS Advokatbyrå’s tax practice. The team assists with structuring issues arising from corporate transactions, real estate acquisitions and company restructurings.