Sweden's government has announced a legislative proposal to amend the country's controlled foreign company (CFC) rules to comply with the EU Anti-Tax Avoidance Directive (ATAD1). In general, the Swedish government considers that the main aspects of Sweden's CFC rules are already compliant with the Directive, including the 25% ownership threshold and the low-tax threshold of 55% of the Swedish rate, although certain important amendments are included in the legislative proposal. One of the main amendments is a new whitelist of jurisdictions where income is automatically considered not to be low-taxed for the purpose of applying the CFC rules. Of particular...