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Sweden Consulting on Tax Proposal to Extend Hybrid Mismatch Rules in Line with BEPS Action 2 and ATAD

08 February 2019

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Proposed Changes

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Sweden

Sweden's Ministry of Finance has announced the publication of a memorandum on tax proposals to extend the country's hybrid mismatch rules in line with BEPS Action 2 and the EU Anti-Tax Avoidance Directive, as amended (ATAD2). In the memorandum, it is proposed that the provisions of the Income Tax Act be extended to cover more hybrid mismatch situations and that the provisions also cover expenses other than interest expense (Sweden introduced new hybrid rules for interest expense from 2019). It is also proposed that the scope be extended to include arrangements that have been concluded for the purpose of incurring...