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An analysis from Skeppsbron Skatt, Taxand Sweden
Sweden has signed a new tax treaty with the Netherlands and protocols amending its existing treaties with Ireland and Cyprus, reflecting a broader effort to modernise cross-border tax rules and strengthen anti-abuse measures. The changes align the agreements more closely with current OECD standards and introduce new safeguards against treaty shopping and tax avoidance.
The new Sweden-Netherlands treaty includes significant changes for individuals and businesses, including revised rules for the taxation of pensions, extended taxing rights on capital gains following emigration, a lower ownership threshold for withholding tax relief on dividends, and broader provisions covering senior management roles. Several older treaty articles have also been removed.
Meanwhile, the Ireland and Cyprus protocols introduce principal purpose tests, updated treaty preambles, and enhanced dispute resolution procedures, including arbitration in certain cases. Businesses and individuals with international operations should review existing arrangements, as the reforms could affect the taxation of pensions, dividends, capital gains and other cross-border activities.
Pernilla van der Capellen, Agnes Fröjd Almefjord and Anders Lagerholm from our Swedish member firm, Skeppsbron Skatt, provide a comprehensive analysis of the new tax treaty updates, which you can read here.
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Cyprus | Ireland | Netherlands | Sweden | Cross border | International Double Taxation | OECD | Tax Treaty