International Business Taxation

The Swedish taxation system is subjected to extensive influence from abroad. The consequences of growing international legislation are examined in this area of research.

The Swedish membership of the EU has resulted in that Swedish legislation must consider case law from the European Court on the freedom of movement. In this tax area there are also a number of directives which to a significant degree influence national law, for example in areas of VAT and cross-border restructurings of group companies.

The tax treaties of international law are also of major importance for Swedish industry as they among other things result in lower withholding tax abroad on income from dividend, interest and royalties.

An essential question is which methods should be used to allocate income to permanent establishments, which is a common form of establishment abroad for, among others, banks. According to new guidelines from the OECD the special transfer pricing rules shall now also apply for pricing in relation to permanent establishments.

In practice, however, there are no Swedish rules for how this should be implemented. Another key issue concerns the balancing of accounts within group companies. Essential case law is available from the European Court and in addition there is a specific proposal from the European Commission regarding a common tax base for companies within the EU.

The taxation of individuals in cross-border situations is also dealt with in this field and it is obviously of importance for companies how their employees are taxed. The taxation of border crossers between Sweden and Denmark as well as the meaning of "substantial attachment" to Sweden are dealt with in this subarea. The research group has extensive international cooperation with foreign researchers.

Programme Manager: Mattias Dahlberg