Sweden is a fully tax
compliant jurisdiction with a very large global network of
double tax treaties and has an advantageous company law. Nor
is Sweden immediately considered as a traditional ‘tax
planning jurisdiction’. This provides Sweden with an
excellent platform for the establishment of international
holding structures. Major advantages of a holding company
No taxation on dividends received from business shares.
No withholding taxation on interest paid.
No capital gains taxation from sales of business shares.
Interest paid by the holding company is tax deductible.
No thin capitalisation rules.
No tax on capital contributions and transfers and no stamp
Losses may be carried forward indefinitely.
Dividend Distributions from Sweden to Curacao Swedish tax
advisors are of the opinion that since the introduction of its
New Fiscal Framework (i.e. imposing a corporate income tax rate
of 34.5%) distributions from Sweden to Curacao qualify for the
withholding tax exemption. Legal opinion on this structure can
be provided on request.
Swedish Income Tax on Dividends Received Dividends
received by a Swedish company from a business-related subsidiary
will be exempt from Swedish corporate income tax regardless of
the level of shareholding and holding period. All non-listed
shares are always considered business shares. For listed shares,
the exemption requires at least 10% share ownership and a
minimum holding period of 12 months.
Swedish Controlled Foreign Corporation (CFC) Rules The
Swedish CFC rules apply if the income of the participation is
taxed under a low tax regime. The threshold for a ‘low-tax’ rate
is below 15.4%. If the income is considered CFC income, the
Swedish parent will be taxed in Sweden on its share of the CFC
income. Tax liability occurs regardless whether the income has
actually been distributed to the Swedish shareholder.
Swedish Withholding Tax on Dividends Distributed
Dividends distributed from a Swedish company will be exempt from
Swedish withholding tax provided the foreign receiver of the
dividends is a company, taxable in its own jurisdiction in a
manner similar to the taxation of dividends in Sweden and the
receiving entity is of a similar kind of structure such as a
share/limited company. In general, the rate has been defined as
an income tax rate of at least 15.4%.
Swedish Capital Gains Taxes Regarding a Sale of
Shares/Liquidation A Swedish company can realise capital
gains without any capital gain taxation. Capital gains from the
liquidation of business-related shares are exempt from corporate
income tax. For publicly listed shares, the exemption requires
at least 10% share ownership and a minimum holding period of 12
months. However, the tax exemption does not apply where the
participation has been subject to the Swedish CFC rules.