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Sweden Announces that Participation Exemption Not Applicable for Dividends Received from a Tax Haven

08 September 2015

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Approved Changes

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Sweden

On 28 August 2015, the Swedish Tax Agency announced that the country's participation exemption for dividends received does not apply when received from a resident of a tax haven not subject to corporate income tax. The reasoning follows one of the main requirements of the participation exemption that the non-resident distributing the dividend must have a similar form and function as a Swedish limited liability company (AB). If the foreign entity is not subject to corporate income tax, it may not be considered similar to an AB and the dividend is therefore not eligible for the exemption.