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Swedish Tax Agency Publishes Response Document to Proposed Interest Deduction Restriction Measures

04 October 2017

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Proposed Changes

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Sweden

On 25 September 2017, the Swedish Tax Agency (Skatteverket) published a response document to the Ministry of Finance's proposed tax measures on interest deductions restrictions ({News-2017-06-22/P/3-previous coverage}). According to the document, the Tax Agency: Recommends adopting an EBIT-based interest deduction restriction model instead of an EBITDA-based model; Recommends the introduction of rules limiting interest expense deductions in cases of hybrid mismatches, but with additional clarifications regarding jointly taxed persons; Recommends targeted interest deduction limitation rules for interest payments to EEA and treaty countries, but proposes that interest deduction would be disallowed if the transaction is "mainly" for the purpose of...