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Amending Protocol to Tax Treaty between Sweden and the UK Signed

25 February 2021

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Treaty Development

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Sweden-United Kingdom

On 23 February 2021, officials from Sweden and the UK signed an amending protocol to the 2015 income and capital tax treaty between the two countries. The protocol is the first to amend the treaty and includes the following main changes: The title and preamble are replaced in line with OECD BEPS standards; The specific main purpose tests limiting benefits of Articles 10 (Dividends), 11 (Interest), 12 (Royalties), and 20 (Other Income) are removed; Article 23 (Mutual Agreement Procedure) is updated with a new paragraph 1, which provides that where a person considers that the actions of one or both...