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Sweden | CJEU rules Swedish withholding tax on dividends to foreign public pension funds is contrary to free movement of capital

13 September 2024

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Tax Alerts, National/Federal Taxation, G...

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Sweden

The Court of Justice of the European Union has held that Sweden's imposing withholding tax on dividends paid to foreign public pension funds, while allowing dividends to pass tax-exempt to Swedish public pension funds, is contrary to the free movement of capital.Based on the decision, foreign public pension funds and state investors that have paid Swedish withholding tax will want to assess whether to file a reclaim. Executive summaryOn the 29 July 2024, the Court of Justice of the European Union (CJEU) ruled in Keva, et al. v. Skatteverket, C-39/23, that it is contrary to the free movement of capital for...