Last year, we indicated that we might see new interest limitation rules during 2016. So far nothing has been announced. However, a proposal may still come during the autumn.
Nevertheless, as presented below, there is new legislation and case law of general interest since the last edition of World Tax. It should also be noted that there are several work streams at the Ministry of Finance (MoF) that we expect will result in significant changes to the tax legislation in the near future. Many of the work streams, but not all, relate to the OECD's BEPS Project. These are the most important ones:
It is also notable that in April 2016, the Swedish Finance Minister, Magdalena Andersson, announced a program for combatting tax avoidance. The issues raised by the finance minister comprise many of the BEPS action points. However, the program also includes several Swedish-specific measures. The main points in the program can be summarised as follows:
Some of these initiatives may result in new legislation in the year to come.
To comply with the recent introduction of articles on anti-avoidance situations in the EU Parent-Subsidiary Directive, the MoF proposed in April 2015 that the Swedish general anti-avoidance rule (GAAR) should also be applicable to matters concerning tax under the Withholding Tax Act (WTA). The proposal was, however, heavily criticised and the MoF decided to revise it. In the amended proposal the idea on applying the GAAR also on withholding tax was abandoned. Instead, the specific anti-avoidance rule in the WTA remained unchanged. The specific anti-avoidance rule states that a person that is otherwise not liable to withholding tax is still liable to tax if the shares are held for the purpose of allowing another person to gain a reduction of the tax. However, the MoF suggested a technical change concerning the application of the specific anti-avoidance provision. It was clarified that the anti-avoidance rule takes priority over the specific exemptions in the WTA. The MoF's revised proposal was approved by the Swedish parliament and is applicable on dividends paid on January 1 2016 and later.
The new legislation may have an impact especially on structures with international holding companies receiving dividends on their Swedish shareholdings. Historically, the recipient of the dividend has often relied on a specific exemption to reduce the Swedish withholding tax from the statutory rate of 30% (possibly reduced under an applicable tax treaty) to zero. Two of the more widely-applied exemptions concern dividends on: (i) shares held by an EU company representing at least 10% of the shares in the distributing company; and (ii) business related shares, as defined in the Income Tax Act, held by a foreign company (a legal entity subject to tax and covered by a Swedish tax treaty or subject to a tax similar to the Swedish corporate tax in its jurisdiction).
Although it was stressed in the government Bill that the recent change was merely a "clarification" of what in essence was already implied in the legislation, there is, in our view, an increased risk that the specific anti-avoidance rule could be applied in situations where the holding company has limited substance and pays dividends to a group company that would have been subject to Swedish withholding tax should it have received the dividend directly.
Withholding tax in the context of holding structures has not in the past been a focus of the Swedish Tax Agency (STA). However, due to the recent changes and the ongoing work on the OECD's BEPS Project, withholding tax matters may attract more interest in the future. In light of this, it may be prudent for international groups owning shares in Swedish companies via international holding structures to review their setup from a Swedish tax perspective. Groups which do not do so could find themselves between a rock and a hard place when both the Swedish interest limitation rules and the changes to the WTA are taken into consideration. The interest limitation rules may preclude tax deduction for intra-group interest expenses, whereas dividends paid could risk suffering Swedish withholding tax.
There is a government Bill pending the approval of the parliament which would introduce a Swedish tonnage tax regime as of January 1 2017. The purpose of the regime is to aid the Swedish maritime industry by allowing a notional taxation on income from maritime business. One of the requirements for being viewed as conducting a maritime business is that the minimum gross tonnage of the vessel is at least 100 tonnes. Taxation in accordance with this regime will be voluntary, but subject to the approval of the STA. Once within the regime no exit is allowed for a 10-year period. It is required that all companies conducting maritime business within the group must enter the tonnage regime.
Under the proposed tonnage tax regime, no tax is levied on any income related to the company's maritime operations. Instead, a notional income is calculated as a percentage of the vessels net tonnage (between 2.01% and 7.82% assuming that the vessel has been operated the entire year and depending on the vessel's net tonnage). The notional income is then included in the company's basis for income tax (statutory tax rate of 22%). Any deferred tax liability relating to the vessels upon entering the regime must be reversed over a maximum period of 20 years, unless certain exceptions apply. Further, the proposed tonnage tax regime includes rules to prohibit that income is shifted between tonnage taxation and the ordinary corporate income taxation regime.
In June 2016, the Supreme Administrative Court (SAC) delivered a new ruling on the arm's-length principle that arguably changes case law. The case concerns two group companies that renegotiated loan agreements. The loans were entered into in 2003 and were subsequently renegotiated in 2008. After the renegotiation, the terms of the loans (the interest rate) became less favourable for the Swedish entity, though both the previous and the renegotiated agreements were considered by the SAC to be at arm's length when looked at in isolation.
The SAC stated that the arm's-length principle can be applied on terms and conditions that in themselves are at arm's length if they do not reflect the conduct of independent parties in relation to what previously have been agreed between the parties. Thus, not only should the interest rate level be the basis for the assessment, but all of the terms and conditions that the parties agreed upon historically and which are still in place. It is important to clarify that the SAC has judged on the renegotiation of the agreements and not whether the previous agreements are arm's length or not. The judgment should therefore only be regarded as applicable as guidance in situations where an arm's-length agreement is replaced by another arm's-length agreement.
The STA has published comments on the SAC's judgment, indicating that the judgment is consistent with the its view. However, the STA considers that it is possible for companies to change agreements concluded on non-arm's-length terms to what would have been arm's length terms when the agreement was concluded, without historic adjustments.
In earlier case law, only the arm's-length nature of the renegotiated terms have been considered, on the grounds that the renegotiated loan (and interest rate) formed the basis for the tax return submitted by the taxpayer. This also follows from the Swedish law doctrine on the defined nature of the tax year (beskattningsårets slutenhet). Under this doctrine, only matters occurring during a specific tax year should be considered in respect of a given tax return. The SAC ruling may arguably provide the STA with an argument for disregarding this doctrine.
It can be argued that this ruling implies a more extensive interpretation of the arm's-length principle than before, but it has yet to be shown what the consequences will be and how this case law will be applied.
In April 2016, the STA presented a proposal on the implementation of the new documentation requirements relating to OECD BEPS Action 13, Transfer Pricing Documentation and Country-by-Country Reporting. The proposal includes master file, local file and country-by-country (CbC) reporting. Under the proposal, CbC reporting will be required for the fiscal year starting on or after January 1 2016, by multinational groups with total revenue of at least SEK7 billion ($820 million). CbC reports shall be submitted for the first time by December 31 2017 for the fiscal year beginning January 1 2016 or later.
According to the proposal, multinational groups with more than 250 employees and which either have a group revenue of at least SEK 450 million or total assets of at least SEK 400 million in the preceding year will be required to submit a master file and local file for the fiscal year beginning on or after January 1 2017. Trading companies exceeding these limits will also be subject to the documentation requirements. The proposal is expected to be accepted by the Swedish parliament in Autumn 2016.
The OECD BEPS Actions 8-10, Aligning Transfer Pricing Outcomes with Value Creation, were published in October 2015. In line with the comments from the OECD, the STA has stated that it considers the report to be applicable retroactively as the amendments and additions are mere clarifications of the arm's-length principle.
The possibility for a member of a Swedish group to pass on non-deductible VAT to other entities within that group, for VAT recovery, ended on January 1 2016. The SAC had in a earlier ruling decided that the legislation was not compatible with either the VAT Directive or the Treaty on the Functioning of the European Union (TFEU). On this basis, the rule was abolished.
The national Swedish pass-through rule (slussningsregeln) made it possible for an entity providing VAT exempt services to pass on parts of its non-deductible VAT to other entities within the same group for VAT recovery. This was possible when the VAT-exempt service was provided to another group member who in turn used this service for its business subject to VAT. For example, the rule was often applied on intra-group letting of premises, and for captive and treasury functions.
The Swedish Tax Agency (Skatteverket) has adopted a more aggressive approach towards taxpayers over the past decade which has resulted in an increase in litigation. Because of this, uncertainty is spreading among companies, who are trying to grasp the complexity of the changing international tax climate and the tax authorities' approach.
"Instead of trying to outright change the law, [the authorities] are challenging individuals and individual companies through the Swedish courts to create precedents while simultaneously using the media to influence public opinion, creating tension for our clients," said Tina Zetterlund, head of tax at KPMG.
Linked to the changing tax market, the matters of transparency and the OECD's BEPS Project have been high on the agenda in Sweden. As a result of the common reporting standard (CRS) discussion, as well as LuxLeaks, the Panama Papers and the overall increased international focus on tax avoidance, the Swedish market has become more nervous. The level of negative publicity of large multinationals has increased this year, and many advisers feel that the national media typically treats such tax affairs unfairly.
"We see clients getting more and more cautious about tax planning," said Magnus Larsson, head of tax at Deloitte. "Most of them are now taking a few steps back, they don't want to be out there in the debate."
The focus on transparency has created an increase in the demand for tax advisory services and it has been a busy year for tax professionals. "In Sweden we are seeing a significant increase from a variety of stakeholders addressing tax as a sustainability issue," said Zetterlund. "From the media, to investors, to the Head of the Swedish Tax Agency, the continued focus on tax transparency and sustainability will keep these issues at the top of the agenda for the foreseeable future."
Although Sweden has been very much been on top of BEPS and the discussions have continued to keep advisers busy, the Swedish market saw very few legislative changes. "From a legislative point of view, Sweden has been a little bit slow but there are things coming. There are some proposals that people are waiting for," said Per Wiker, head of tax at Magnusson.
The government has implemented the amended EU Parent-Subsidiary Directive into domestic legislation with effect from January 1 2016 and it is unknown whether Sweden's CFC rules will be amended. On April 29 2016, Skatteverket submitted a proposal to the Ministry of Finance suggesting the implementation of the OECD's transfer pricing documentation and country-by-country reporting.
New interest deduction restrictions are expected to be introduced in 2017, a measure which has been high on the agenda for the past couple of years. "Again this year, there has been a lot of work relating to the Swedish rules of interest deduction which are unclear and there's a lot of tax litigation going on in that area," said Mac Berlin, head of tax at Skeppsbron Skatt. "Some of the really major cases we have been involved in, but there is a lot of litigation going on here, so that's a theme for this year as well."
In 2015, the European Commission claimed the Swedish interest deduction rules did not comply with EU law and caused uncertainty, particularly among international investors.
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Mannheimer Swartling is the largest law firm in the Nordic region and regularly receives instructions on Sweden's most prominent and complex financial and corporate law matters. The firm's position on the market across all practice areas is frequently confirmed by rankings in the league tables and awards institutes.
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|Corporate Income Tax||22%|
|Capital Gains Tax||22%|
|Net Operating Losses (years)|
|Royalties from, for example, patents, know-how||0%||22%|
|Branch Remittance Tax||0%|
Source: Skeppsbron Skatt, Taxand Sweden
Johan Myrén and Anna Romell Stenmark are key professionals at Advokatfirman Lindahl, a full-service firm that supports clients in a range of matters such as tax litigation, compliance, commercial dispute resolution, capital markets and M&A.
Its clientele comprises Swedish enterprises and multinational companies, high net-worth individuals, and family businesses and clients in several industries including banking and finance, construction, energy, environment, IT, media and life sciences.
The tax practice at Baker & McKenzie is overseen by Linnea Back who practices in the areas of tax litigation and tax reorganisation for national and international companies as well as small and medium-sized enterprises. The team comprises three professionals and has significant international experience and benefits from more than 900 tax experts around the world, enabling it to draw on foreign expertise.
The firm supports clients in several areas of tax, with a key focus on restructuring, Swedish and international tax planning for multinational companies, joint ventures, real property taxation and tax litigation. Particular industry specifications include digital, financial services and healthcare/pharmaceuticals.
This year, Patrik Sedlar joined the firm from PwC as an associate. He assists foreign and domestic clients in various tax matters related to Swedish income tax with a focus on corporate tax and transfer pricing.
Carl-Magnus Uggla leads the tax practice at Bird & Bird comprising five other fee earners. Uggla joined the firm with more than 16 years of transactional expertise, mainly from the real estate and private equity industry. He joined from Hannes Snellman where he was a specialist partner and head of tax. He has extensive experience in transactions and tax planning as well as tax controversy, and specialises in real estate funds, institutional real estate owners and listed real estate companies. Uggla's clientele also includes construction companies, multinational enterprises and private equity companies.
The Bird & Bird tax team offers a broad range of knowledge in all areas of tax with a number of senior professionals including Victor Stålblad, who has worked for the Swedish tax agency for more than nine years and has a wealth of experience of incentive schemes. Staffan Andersson has more than 35 years of experience and has worked as the head of tax at PwC in Sweden and as a legal expert at the Swedish Ministry of Finance. He has significant experience in entrepreneur tax issues and migration.
A client said: "I would recommend the team at Bird & Bird to others due to their thorough work, knowledge within the area, ability to see the overall picture and that they are nice to work with."
The team offers a range of services including international tax planning, restructurings, transfer pricing and supply chain solutions as well as expertise in setting up group structures and real estate holding structures.
Magnus Larsson leads the Deloitte tax practice in Sweden which houses a full suite of tax services including tax management consulting, international tax, transfer pricing, business tax, indirect tax, private company, legal advisory and M&A.
The large team is supported by tax, legal and accounting professionals with extensive knowledge and understanding of Swedish and international tax law. The firm provides tax solutions to corporates, individuals and high net-worth individuals on a range of tax matters such as tax risk and business management, tax strategy development, structuring and implementation for complex transactions and global compliance.
During the past couple of years, the Swedish M&A tax practice has grown and the team advised on many large Swedish transactions, including the cross-border merger between Santander Norway and GE Money Bank. The firm also increased its focus on digital tax solutions and is developing tools and investing in the knowledge management area.
Deloitte's transfer pricing team, headed by Elvira Allvin, has also continued to grow and offers a full range of transfer pricing services.
Managing partner Stefan Lindh is a key member of the commercial law firm Delphi, which is based in five cities in Sweden: Stockholm, Göteborg, Malmö, Linköping and Norrköping.
Lindh has a wealth of experience advising clients in corporate taxation, M&A and private equity matters. His tax team offers a range of services and supports clients on tax aspects concerning anti-corruption, compliance, insolvency, dispute resolution, IP and related arbitral court proceedings.
DLA Piper's head of tax Erik Björkeson has more than 17 years of experience working with national and international tax law. The tax practice consists of five professionals, including two partners, and frequently provides high end tax advice on M&A transactions as well as assisting a range of Swedish corporate entities.
One client said the team "provides good, timely advice and is an alternative to the Big 4 with equal tax expertise".
In one deal, the firm assisted Scandlines with the preparation of a ruling submitted with the Swedish board of advance rulings. The team worked closely with other DLA Piper practices on the client's cross border operations and included complex VAT issues.
As part of the international DLA Piper network, its clients benefit from both domestic and global tax expertise.
EY's tax practice in Sweden is jointly headed by Mikael Hall and Carl Pihlgren and offers a full array of tax services for corporate clients and organisations as well as private clients throughout the Nordics. Its services include income tax, indirect tax and customs, transaction tax, international tax, transfer pricing, tax policy and controversy and law.
The firm assists clients across all industries with private equity, industrial products, real estate and financial services, oil and gas, and diversified industrial products.
Over the past year, the large team, which comprises 26 partners and 258 professionals, supported clients in a range of projects including a large cross-border merger, VAT analytics and a dispute around the allocation of shares and debt to a Swedish branch of a foreign entity.
EY is fully integrated into the global network and is very active with respect to CRS, FATCA and OECD by providing both by supporting clients within the financial sector, private equity and industrial market on compliance and publishing several Swedish articles on the topic.
Grant Thornton's tax department consists of 85 professionals offering a full scope of tax services. Monica Söderlund leads the group, which assists domestic and foreign corporate clients on transaction and interest deduction. Professionals at the firm have extended knowledge of Swedish and international taxation with an emphasis on international tax planning, VAT and other indirect taxes, transfer pricing, profit extraction and repatriation.
In one deal, the team assisted a large Swedish property group in a property transaction involving numerous properties in combination with exchange transactions.
The practice is part of the global Grant Thornton network and has offices in 10 locations throughout Sweden. This year, 12 new professionals joined the department including Uwe Scheele and Sofia Almén from EY.
KPMG's tax team comprises 159 professionals and offers a full range of tax services to corporate and individual taxpayers operating in Sweden and abroad. The team, headed by Tina Zetterlund, has a diverse background in both Swedish and international tax, legal and fiscal consulting.
This year, six new professionals joined the team, including Pontus Fornell who joined from Nordea where he was the global head of indirect tax, Johan Rick from the Administrative Court of Appeal and Björn Johansson, who re-joined KPMG from his own business to act as a full-time tax business development manager.
Maria Andersson and Petter Frödeberg were promoted to partner, bringing the total number of partners at the firm up to 15.
A client said: "In my opinion KPMG is the best corporate and international tax firm in Sweden – certainly of Big 4. I certainly would and have recommended KPMG Sweden to others. Technical quality and service delivery are the reasons."
In one deal, the team provided tax structuring for two of Sweden's five national pension funds in the creation of a joint venture with a US teachers' pension fund to invest in European office properties.
Mats Anderson leads the Linklaters' Nordic tax team and has experience in private and public M&A, capital markets, real estate and private equity. He also has knowledge of tax litigation and advises on VAT and regulatory tax issues. The tax practice in Sweden offers a wide range of services to clients from across an array of industries including private equity, financial, industrial, health care and pharmaceutical, energy and infrastructure, and media. The professionals at the firm are experts in Swedish and international tax, corporate tax, M&A, cross-border taxation, and compliance.
Magnusson's tax practice has a wealth of experience and offers a full range of advisory services which includes transactions structures, restructuring and organisations, international taxation, tax planning, tax due diligence, financial services tax, tax compliance and tax disputes.
The team is headed by Per Wiker, who has previous experience from Deloitte and Grant Thornton, and specialises in corporate and international tax law, civil law and accounting issues as well as disputes against the authorities. Eric Cederström is the firm's other tax partner. His key practice areas include corporate tax, international tax, tax issues in relation to fund formation, regulated investment funds, private equity funds and debt funds.
A client described their experience with the team as "experienced, prompt delivery, hands-on advice and on budget".
In one deal, the firm advised one of the Nordics largest real estate funds on the set up of a new fund, including tax structuring work and complete advice in relation to profit split mechanism.
Martin Nilsson is the head of Mannheimer Swartling's corporate taxation practice group and focuses on tax matters related to the sale of companies and real estate, restructuring, private equity and financing. The tax practice offers assistance in a range of activities including international tax, transactional tax, transfer pricing, real estate investments, finance structuring, takeovers and cross-border transactions.
Its practitioners have knowledge of several areas of taxation as well as years of experience in consulting, litigation and business tax. The firm regularly assists clients on large projects such as M&A, fund establishments, incentive programmes and also advises on routine tax matters and conduct tax litigation.
Charlotte Nordling Hybinette is the managing partner at MAQS Advokatbyrå and specialises in property transactions and general business law. The firm advises companies on national and international corporate tax, VAT, restructuring, tax planning, transactions, double taxation agreements and the development of secondment and incentive programmes.
The tax department at PwC is overseen by Mikael Carlén who is supported by a large team of tax professionals with extensive knowledge in law, accounting and economics. The team comprises 333 professionals, including 36 partners, and is one of the largest tax practices in Sweden. Johannes Ernst joined the firm from EY in January 2016, bringing extensive expertise in international and Swedish corporate tax, tax accounting, compliance, reporting, and project management and planning and restructuring to the team. Lisa Danielsson formerly worked for Baker Tilly Tributa and joined the firm in April 2016 along with Rubia Monteiro who was appointed tax senior manager in June 2015.
The firm offers a full range of services with expertise in advising clients from the private equity, retail, real estate, financial services, and engineering and construction industries.
Sören Brekell is a tax expert with extensive experience in restructuring of medium-sized and large companies as well as tax proceedings, inheritance tax, removals and fissions. He leads the tax team at Setterwalls, which encompasses years of expertise in corporate, fiscal and tax law. The firm has offices in Stockholm, Göteborg and Malmö and supports clients in various aspects of taxation with focus on M&A, tax litigation and restructuring.
Skeppsbron Skatt, Taxand Sweden is described by clients as easy to work with and consisting of high quality advisers. Managing partner Mac Berlin leads the tax team of 36 other professionals which offers a full range of corporate tax services including business tax, direct and indirect tax, tax management consulting, tax compliance and tax accounting. The team has years of experience in tax advisory and specialise in tax litigation, structuring and transactions.
Professionals at the firm have broad expertise across several industries but are particularly strong in industrial production, financial services and insurance, real estate, building and construction, and state-controlled companies and institutions.
In one deal, the team assisted AMF Fastigheter on the acquisition of real estate in Norway, involving complex joint venture investment in real estate.
Berlin's expertise is in international taxation, Swedish corporate tax and transactional taxation. He has previous experience working for EY and has been with Skeppsbron Skatt, Taxand Sweden since 2004.
Viktor Sandberg heads the tax operations at Svalner, working closely with eight other partners and 33 professionals. The full-service firm has expertise in VAT and indirect tax and has particular emphasis in the real estate and construction, and private equity industries, as well as banking and finance, health care and telecommunications.
Fredrik Berndt has been appointed partner at Svalner, joining from Mannheimer Swartling and has engaged in a number of high-profile litigation cases in the private equity sector. Nine other professionals also joined the firm from KPMG, Folksam, and EY as well as from university.
The team assisted KLP Eiendom in an acquisition valued at approximately SEK 1.75 billion ($209 million). Norwegian KLP Eiendom acquired the large commercial property Waterfront Hotel and congress facility located in the centre of Stockholm from Norwegian DNB Liv. It is one of the largest Swedish hotel transactions in 2015.
The firm is a member of the global WTS network operating in more than 100 countries, dedicated to tax, legal and consulting.
Vinge's tax group has a wealth of experience providing expert tax law advice and has key strengths in advising on private equity funds, debt funds and similar investment structures. Ulf Käll and Mattias Schömer are the key contacts for the tax department and are both members of the Swedish Bar Association.
The team provides assistance in a range of domestic and international tax matters including restructurings, project financing and issues relating to emigration and repatriations. It also assists clients on VAT and other indirect tax matters.
Wistrand's tax department of experienced tax professionals have experience in tax and legal consulting. The tax practice comprises eight partners and 11 professionals with extensive expertise of Swedish and international tax law. It supports clients with a wide range of tax services, including corporate, private and capital taxation, business taxation, tax litigation, investment funding, restructuring and cross-border taxation.