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Sweden Interest Deduction Restrictions Proposed with Corporate Tax Rate Cut

22 June 2017

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Proposed Changes

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Sweden

The Swedish Ministry of Finance has proposed corporate tax reform measures, including the introduction of new interest reduction restrictions and hybrid mismatch rules along with a cut in the corporate tax rate. The proposed measures include: A general EBIT-based interest deduction restriction of 35% of EBIT with an SEK 100,000 safe harbor deduction limit and allowed carry forward of excess interest up to six years, as well as an alternative proposal for an EBITDA-based interest deduction restriction of 25% of EBITDA; A temporary limit for the offset of carried forward losses to 50% of taxable profit for two years if...