ARTICLE · 23 OCTOBER 2026

A Statutory Definition Of Permanent Stay In Sweden

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Sweden is introducing a statutory definition of permanent stay to replace the current unpredictable case-by-case assessment. The new rule establishes clear day-count thresholds for determining unlimited tax liability, fundamentally changing how cross-border workers and property owners are taxed.

SwedenTax

Victor Elovsson

Ebba Perman Borg

On 1 September 2026, the Swedish government presented a proposal to introduce a statutory definition of permanent stay (Sw: “stadigvarande vistelse”) in the Swedish Income Tax Act (prop. 2025/26:306). See the bill here.

Permanent stay is one of three grounds for unlimited tax liability in Sweden, alongside residence and essential ties. The term is currently undefined in the Income Tax Act. Under preparatory works and HFD case law, a continuous stay of six months or more is in principle regarded as permanent, while shorter stays are assessed based on their length, extent and regularity. The assessment has proven unpredictable: temporary interruptions are counted into the stay, recurring stays each shorter than six months can qualify, and a person can be regarded as staying permanently in Sweden even in years when they spend fewer days in Sweden than abroad.

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