SWEDEN Law and Practice Contributed by: Christoffer Dahl, Niclas Söderlund, Michel Weimer and Björn Mårtensson, XR Legal
8.3 Mandatory Binding Arbitration The STA promotes the use of so-called “prelimi - nary discussions” for the clients of the Large Tax - payers’ Office, ie, mainly companies belonging to a larger group. With respect to the tax treatment of the transaction, the taxpayer is normally, in the pre - liminary discussions, advised to apply for an advance tax ruling from the Council for Advance Tax Rulings (Sw: Skatterättsnämnden ).
Businesses may apply for an APA regarding future intragroup transactions for income tax purposes. The application must include sufficient information, and the transactions must be significant and capable of being assessed independently. A pre-filing meeting with the competent authority is possible. An APA is binding for the STA in relation to the trans - actions covered if its conditions are met, but it may be amended or revoked in certain circumstances. 9.2 Other Mechanisms No additional information has been provided.
9. Dispute Prevention 9.1 Advance Pricing Agreements
Bilateral or multilateral advance pricing agreements (APAs) can applied for from the STA for a fee between SEK100,000 and SEK150,000. Sweden does not pro - vide unilateral APAs. It is generally required that Swe - den has a tax treaty with the other relevant jurisdic - tions.
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