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Europe
UK-Sweden tax treaty enters into force
The UK-Sweden tax treaty, signed March 26, 2015, entered into force on December 20, 2015, HM Revenue and Customs announced January 13. The treaty . . .
Belgium
EU committee publishes letters from 13 nations on tax ruling practices
A European Parliament committee has published letters from EU member state officials describing tax ruling practices, efforts to combat tax avoidance, and compliance with EU spontaneous exchange of information directives. The letters, published by. . .
Europe
UK and Sweden sign double tax treaty
The UK’s HM Revenue and Customs on March 30 announced that the UK and Sweden signed a double tax treaty on March 26. The agreement . . .
Asia-Pacific
Hong Kong signs TIEAs with Denmark, the Faroes, Greenland, Iceland, Norway, and Sweden
Hong Kong signed tax information exchange agreements with six jurisdictions on August 22: Denmark, the Faroe Islands, Greenland, Iceland, Norway, and Sweden, according to . . .
Asia-Pacific
Japan-Sweden protocol to enter into force October 12
The requirements for the entry into force of the protocol between Japan and Sweden, signed December 5, 2013, were met on Sept. 16 and the treaty will enter into force on October 12, Japan’s Ministry of Finance has announced.
The protocol sets a zero rate of withholding on interest and royalties. The withholding rate for dividends is zero for corporate shareholders that hold at least 10 percent voting power, and is 10 percent in other cases.
The protocol also adds measures to prevent abuse of the treaty, introduces an arbitration proceeding to the mutual agreement procedure, and expands exchange of information. Release, Protocol (66KB).
Europe
Sweden proposes to limit participation exemption, toughen withholding tax antiabuse rules
The Swedish government, on April 22, proposed legislative amendments that would disallow a tax exemption for dividends paid to a Swedish company that can be deducted as interest by the distributing company and that would strengthen antiabuse rules pertaining to withholding taxes, writes EY in an April 24 Global Tax Alert. See, EY.
European Court of Justice
ECJ rules that intragroup services provided by US company to Swedish branch are subject to VAT, hitting global financial firms
A European Court of Justice (ECJ) judgment, released Sept. 17, will result in large VAT bills for banks, insurers, and other businesses considered VAT-exempt.
The decision, Skandia America Corp. v. Sweden, concludes that supplies of services from a non-EU company to its EU branch are subject to VAT when the branch belongs to a VAT group. Previously, provision of these services . . .
Update: For UK government’s October 14 reaction to Skandia, see HM
Revenue and Customs Brief 37 (2014) – VAT grouping rules
