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Sweden Adopts Legislation Amending Participation Exemption and Anti-Avoidance Rules

17 December 2015

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Approved Changes

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Sweden

Sweden has adopted legislation that includes changes to the country's participation exemption rules and expands the anti-avoidance rules under the Coupon Tax Act (CTA). The legislation is based on changes made to the EU Parent-Subsidiary Directive concerning hybrid mismatches and anti-avoidance, and includes: The participation exemption rule is changed to deny the exemption on dividends received if deductible as interest or similar by the distributing foreign entity; and The anti-avoidance provisions in the CTA are expanded to cover all situations where a foreign person or entity receives dividends, if the holding of the shares is intended to provide an illegitimate...