Sweden Tax Court Issues Advance Notice Clarifying Dividend Taxation Regarding Corporate Restructuring for Transferring Profits

The Swedish Tax Court Nov. 21 issued Advance Notice No. 19-25/D, clarifying the taxation of dividends regarding two corporate restructuring alternatives for transferring profits between companies. The taxpayer, an individual, had qualified shares in two companies. The taxpayer sought clarification on whether two different procedures carried out for the purpose of transferring profits between the two companies would trigger dividend taxation for the taxpayer, as well as whether the Tax Evasion Act would apply to either of the specified options. The first option would involve transferring profits between companies through share transfers and redemptions, while the second option would involve ...