The Swedish Tax Agency has published comments regarding the offset of foreign tax credits that have been carried forward in cases where foreign income has not been taxed abroad. The comments concern a judgment of the Supreme Administrative Court that was issued on 16 March 2023. The case involved a Swedish company that had a branch in Belgium. In 2012, the company paid Belgian tax on income from the branch that exceeded the company's tax liability in Sweden. In 2017, the company requested that a portion of the excess tax (foreign tax credit) be offset against other foreign income that...