Carl Pihlgren Dunja Brodic The National Board on Advance Rulings recently rendered a decision regarding the Swedish rules on exit taxation and the reversal of tax allocation reserves when a company ceases to be a tax resident in Sweden due to tax treaty provisions. In summary, the Board ruled that the Swedish rules pursue an objective in the public interest, but are nevertheless contrary to the freedom of establishment as they go beyond what is necessary to obtain the objective they pursue.
December 01 2006