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EY +46 (8) 520-590-00 Mail address: Box 7850 103 99 Stockholm Sweden
Street address: Hamngatan 26 Stockholm Sweden
Principal Tax Contact
Katrin Norell
+46 (8) 520-598-07
Mobile: +46 (70) 318-98-07 Email: katrin.norell@se.ey.com
International Tax and Transaction Services – International Corporate Tax Advisory
Erik Hultman
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International Tax and Transaction Services – International Capital Markets
Erik Hultman
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International Tax and Transaction Services – Transfer Pricing and Operating Model Effectiveness
Olov Persson
Business Tax Advisory
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Helena Norén, +46 (8) 520-596-87
Financial Services Organization Mobile: +46 (70) 312-96-87 Email: helena.noren@se.ey.com
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Global Compliance and Reporting
Daniel King
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International Tax and Transaction Services – Tax Desks Abroad
Oscar Kruse
+1 (212) 466-9967 (resident in New York) Email: oscar.kruse1@ey.com
International Tax and Transaction Services – Transaction Tax Advisory
Einar Stigård +46 (8) 520-582-61 Mobile: +46 (70) 200-89-91 Email: einar.stigard@se.ey.com
Johan Agrell
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Per Stenbeck +46 (8) 520-583-17 Mobile: +46 (72) 500-98-73 Email: per.stenbeck@se.ey.com
People Advisory Services
Katrin Norell
Indirect Tax
Anna Berggren
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+46 (8) 520-593-74
Financial Services Organization Mobile: +46 (72) 178-74-74 Email: anna.berggren1@se.ey.com
Martin Carlsson +46 (8) 520-597-79
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Linnea Jacobsen
Tax Controversy
Per Holstad
Legal Services
Paula Hogéus
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Göteborg GMT +1
EY
+46 (31) 63-77-00
Mail address: Fax: +46 (31) 15-38-06 (Tax) 401 82 Göteborg Sweden
Street address: Parkgatan 49 Göteborg Sweden
Principal Tax Contact
Elisabeth Granhage
Business Tax Advisory
Elisabeth Granhage
+46 (31) 63-78-26
Mobile: +46 (70) 315-88-26 Email: elisabeth.granhage@se.ey.com
+46 (31) 63-78-26
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Malmö GMT +1
EY
+46 (40) 693-15-00
Mail address: Fax: +46 (40) 23-70-91 Box 4279 203 14 Malmö Sweden
Street address: Nordenskiöldsgatan 24 211 19 Malmö Sweden
International Tax and Transaction Services – International Corporate Tax Advisory
Tonie Persson
+46 (40) 693-15-44
Mobile: +46 (70) 206-49-94 Email: tonie.persson@se.ey.com
International Tax and Transaction Services – Transfer Pricing and Operating Model Effectiveness
Ulrika Eklöf
Clemens Mader
A. At a glance
+46 (40) 693-15-71
Mobile: +46 (70) 324-97-71 Email: ulrika.eklof@se.ey.com
+46 (40) 693-15-24
Mobile: +46 (76) 607-37-67 Email: clemens.mader@se.ey.com
Corporate Income Tax Rate (%) 20.6
Capital Gains Tax Rate (%) 20.6
Branch Tax Rate (%) 20.6
Withholding Tax (%)
Dividends 30 (a)
Interest 0
Royalties from Patents, Know-how, etc. 0 (b) Branch Remittance Tax 0
Net Operating Losses (Years) Carryback
(a) This withholding tax applies to nonresidents. In general, no withholding tax is imposed on dividends paid to a foreign company that is similar to a Swedish limited liability company (aktiebolag) and that is not regarded as a tax-haven company. If the payer is a company listed on the stock exchange, an exemp tion is granted only if the recipient holds at least 10% of the voting rights of the payer for more than one year. (b) Royalties paid to nonresidents are not subject to withholding tax, but the net income is taxed as Swedish-source income at the normal corporate tax rate. However, under most treaties, the tax rate is reduced. Sweden has enacted legislation implementing the European Union (EU) directive on interest and royalties (2003/49/EC), effective from 1 January 2004. In implementing the directive, Sweden considered the most recent amendments adopted by the European Council.
B. Taxes on corporate income and gains
Corporate income tax. Income from all business activities is aggre gated as one source of income — income from business. In principle, corporate income tax (CIT) is levied on all corporate income of a company incorporated in Sweden (resident corporation), except for certain domestic and foreign dividends (see Dividends). If a Swedish company conducts business through a permanent establishment abroad, the foreign profits are also sub ject to Swedish tax, unless a treaty provides otherwise. Nonresident corporations are subject to tax on Swedish-source income only.
Rate of tax. The corporate income tax rate is 20.6%. No local income taxes are levied on corporate profits.
Capital gains. No separate regime exists for capital gains, but special rules apply to the calculation of the amount of capital gains and losses.
In general, capital gains on shares held for business purposes are exempt from tax (for details regarding shares held for business
purposes, see Dividends). The exemption is also applicable for interests in partnerships as well as shares held by partnerships.
Corresponding losses on interests in partnerships are nondeduct ible. However, capital gains on interests in partnerships domi ciled outside the European Economic Area (EEA) are not covered by the participation exemption.
Taxable capital gains are aggregated with other corporate busi ness income. Capital gains are subject to tax when transactions are closed, regardless of the holding period or when payment is received.
Administration. A company may choose its financial year and is required to file its corporate income tax return by the corre sponding due date for the return. A company can submit its return electronically through the Tax Agency’s e-service or via regular mail. The following table provides the dates for filing the corporate income tax return for all financial years.
Filing of tax return
Financial year Paper filing E-filing
1 February–31 January,
1 March–28 February,
1 April–31 March or
1 May–30 April 1 November 1 December
1 June–31 May or
1 July–30 June 15 December 15 January
1 August–31 July or
1 September–31 August 1 March 1 April
1 October–30 September,
1 November–31 October,
1 December–30 November or
1 January–31 December 1 July 1 August
If any of the dates above fall on a Saturday or Sunday, the filing date is moved to the following Monday.
A financial year may be extended for up to 18 months in certain circumstances, such as for a company’s first or last financial year or if a company changes its financial year.
Advance tax payments are made in monthly installments during the year to which they relate. The final tax assessment must be issued by the Swedish Tax Agency before the 15th day of the 12th month after the end of the assigned income year. Any balance of tax due must be paid within 90 days after the final tax assessment.
Dividends. In general, dividends received from Swedish compa nies on shares held for business purposes are exempt from tax. Dividend distributions on other shares are fully taxable. Shares are deemed to be held for business purposes if they are not held as current assets and if any of the following conditions is satisfied:
• The shares are unlisted.
• The shares are listed and the recipient of the dividends owns at least 10% of the voting power of the payer for more than one year.
• The shares are held for organizational purposes (important to the business of the holder or a company in the same group as the holder).
The same conditions for exemption also apply to dividends received from foreign companies if the distributing foreign entity is equivalent to a Swedish limited liability company (aktiebolag).
Shares held in a company resident in an EU member state are considered to be shares held for business purposes if both of the following conditions are satisfied:
• The company owning the shares holds 10% or more of the share capital of the payer (it is irrelevant whether the shares are held as current assets).
• The payer is listed in Council Directive 2015/121/EU (the Parent-Subsidiary Directive) and is required to pay one of the taxes listed in the directive.
Partnerships may receive tax-exempt dividends to the extent that the dividend would be exempt if received directly by the owners of the partnership interests.
However, if the distributing company is a foreign company that can deduct the dividend payment as interest or as a similar pay ment, the dividend is not exempt for the Swedish receiving company.
Foreign tax relief. Under Swedish law, a Swedish company may usually claim a credit against CIT liability for comparable taxes paid abroad. Sweden applies a so-called “overall” tax credit sys tem. However, certain tax treaties may override internal foreign tax credit rules and instead exempt foreign-source income from Swedish tax.
C. Determination of trading income
General. Corporate income tax is based on taxable business income computed according to the accrual method of accounting. Taxable business income generally includes all worldwide income earned by a corporation. The major exceptions are capital gains and dividends on shares held for business purposes (see Section B).
Inventories. Inventories are valued at the lower of acquisition cost or actual value. Acquisition cost is determined using the first-in, first-out (FIFO) method. An obsolescence provision of 3% is allowed when using acquisition cost to value inventories.
Reserves. A profit allocation reserve allows a 25% deduction of the taxable income for the financial year. Each year’s reserve must be added back to taxable income no later than six years after the year of the deduction. The oldest remaining reserve must always be reversed first. The reserve is based on net income before tax and includes any amounts from the allocation reserve that are added back to taxable income.
Tax is imposed annually on fictitious interest income with respect to the deferred tax amount.
Depreciation. Equipment with a life of three years or less may be written off in the year of purchase. Machinery and equipment may be written off either on a straight-line basis at 20% of cost annually or on a declining-balance basis at 30% of the current tax value. In any one year, the same method must be used for all machinery and equipment. However, companies can switch to a different method each year. The above methods may be used only if the same depreciation method is used in the financial
statements. If this condition is not satisfied, a third method, which is also based on the remaining depreciable value, is available. Under this method, companies may choose any percentage, up to a maximum of 25%. The same amortization rules that govern machinery apply to patents, trademarks, purchased goodwill and other intangible property.
Depreciation of buildings is straight-line over the building’s expect ed life. In general, commercial buildings may be depreciated at 2% to 5% annually, factory buildings at 4% and office buildings at 2%. Buildings subject to greater wear and tear may be depreci ated at higher rates. Accelerated depreciation of 2% annually is allowed for new buildings, additions or reconstructions during a period of six years following completion.
If depreciable machinery and equipment are sold, the proceeds reduce the depreciable base for the remaining machinery and equipment.
Relief for losses. Losses may be carried forward indefinitely. Losses may not be carried back.
The tax law includes rules restricting the use of old tax losses of acquired companies.
In general, the possibility of offsetting the losses of an acquired company through a group contribution (see Groups of compa nies) may in certain circumstances be restricted during a fiveyear period. The rules also include a restriction under which the amount of losses that may be used is limited to twice the amount paid for the shares. Special restrictions also apply to the possibil ity of using losses with respect to mergers.
Groups of companies. There is no consolidated treatment whereby all companies in a group may be treated as a single taxable entity. However, rules permit income earned by companies in a corporate group to be distributed within the group through the use of group contributions, which are deductible for the paying company and taxable income for the receiving company. In general, group contributions may be made between Swedish group companies if ownership of more than 90% exists during the entire financial year. This rule applies even if a foreign parent or subsidiary is in the group structure. A Swedish permanent establishment of a foreign company resident in an EEA state is treated as a Swedish company for purposes of the group contribution rules.
In certain circumstances it is possible for Swedish companies to claim deductions of losses in foreign subsidiaries.
D. Other significant taxes
The following table describes other significant taxes.
Nature of tax Rate (%)
Value-added tax (VAT), on goods (including imported goods but excluding exported goods) and services, unless specifically exempt by law; based on sales price excluding VAT Standard tax rate
Nature of tax Rate (%)
Rate on hotel services, food served in restaurants, foodstuffs (not including alcoholic beverages) and the repair of bicycles, shoes, leather goods, clothing and linen (a legislative proposal to reduce the VAT rate on such repairs to 6% may be approved during 2022) 12 Rate on books and newspapers, music notes and maps, entry to theaters, cultural and sports events, entry to and demonstrations of zoos and demonstrations of certain areas of nature, passenger transportation and certain copyrights 6
Social security contributions, on salaries, wages and the assessed value of benefits in kind; paid by employer General rate 31.42
Special salary tax, on earnings not included in the base for social security contributions; paid by the employer 24.26
E. Miscellaneous matters
Controlled foreign companies. A Swedish company that holds or controls, directly or indirectly, at least 25% of the capital or vot ing rights of a foreign low-taxed entity (controlled foreign com pany, or CFC) is subject to current taxation in Sweden on its share of the foreign entity’s worldwide profits if the ownership or control exists at the end of the Swedish company’s fiscal year. Foreign entities are considered to be low-taxed if their net income is taxed at a rate of less than 11.33% (55% of the effective cor porate income tax rate) on a base computed according to Swedish accounting and tax rules. However, the CFC rules do not apply to foreign entities that are resident and subject to corporate income tax in jurisdictions on the so-called “approved list.” If Sweden has entered into a tax treaty with a jurisdiction on the approved list, an additional requirement for the exemption is that the for eign entity and its income must be eligible for treaty benefits.
Anti-avoidance legislation. A general anti-avoidance act applies in Sweden. The act is considered a source of insecurity to taxpayers because it limits the predictability of the tax law. Under the act, a transaction may be adjusted for tax purposes if all of the follow ing conditions are met:
• The transaction, alone or together with other transactions, is part of a procedure that provides a substantial tax advantage to the taxpayer.
• The taxpayer, directly or indirectly, participated in the transac tion or transactions.
• Taking into account all of the circumstances, the tax advantage can be considered to be the predominant reason for the proce dure.
• A tax assessment based on the procedure would be in conflict with the purpose of the tax law, as it appears from the general design of the tax rules, the rules that are directly applicable or the rules that have been circumvented through the procedure.
Transfer pricing. The Swedish transfer-pricing regulation is based on the arm’s-length principle. As a result, in general, the transferpricing guidelines of the Organisation for Economic Co-operation
and Development (OECD) apply. The Swedish Tax Agency may adjust the income of an enterprise if its taxable income in Sweden is reduced as a result of contractual provisions that differ from those that would be agreed to by unrelated parties and if the fol lowing three additional conditions are met:
• The party to which the income is transferred is not subject to tax in Sweden.
• It is reasonably established that a community of economic inter est exists between the parties.
• It is clear from the circumstances that the contractual provisions were not agreed upon for reasons other than the community of economic interest.
If the conditions under the law are met, the Swedish Tax Agency may increase the income of an enterprise by the amount of the reduction resulting from the contractual provisions that were not determined at arm’s length.
Under Swedish rules, a Swedish company must have formal transfer-pricing documentation in place with respect to crossborder transactions. These requirements have been modified to follow the OECD Base Erosion and Profit Shifting (BEPS) Action 13 recommendations. The modified documentation requirements apply to financial years starting after 31 March 2017 and require a Master File/Local File structure under which one Master File is prepared for the multinational enterprise group, and a Local File is prepared for each country where the group has operations. Small and medium-sized multinational enterprise groups are excluded from the obligation to prepare transfer-pricing documentation. The classification of small and medium-sized companies includes the following companies:
• Companies employing less than 250 persons
• Companies having an annual turnover below SEK450 million or a balance-sheet value below SEK400 million
In addition to the above, aggregated transactions with a counter party that amount to less than SEK5 million per counterparty are deemed “non-essential” and do not need to be documented in the Local File.
Debt-to-equity rules. No thin-capitalization rules exist in Sweden. However, the Companies Act requires the compulsory liquidation of a company if more than 50% of the share capital is lost without replacement of new capital.
Interest limitation rules based on earnings before interest, tax, depreciation and amortization. Sweden introduced major changes to its interest limitation rules as of 1 January 2019, which supersede the previous rules. The new rules, which are based on earnings before interest, tax, depreciation and amortization (EBITDA), are described below.
General limitation. Deductibility of net interest expense is limited to 30% of “Tax EBITDA.” Special rules apply to investment com panies and cooperative associations. These include a safe harbor rule to ease the administrative burden on smaller companies. No limitation is imposed on companies with a net interest expense below SEK5 million. The limitation is applied at the group level,
meaning that the total deductible within a group under the safe harbor rule is limited to SEK5 million.
It is possible to offset net interest income and expense among companies that can exchange group contributions.
A nondeductible net interest expense can be carried forward for six years, but a change of control would forfeit the carryforward. However, this is not the case if the change of ownership occurs between two companies within the same group. The same applies for qualified mergers and demergers.
The inclusion of interest expense in the tax base of certain assets (for example, inventory, buildings, machinery and equipment, and intangible assets) is not permitted.
Targeted limitation. Deduction of interest is subject to further limitations with respect to debt between affiliated companies. Such interest expense is tax-deductible only to the extent the beneficial owner of the interest income is tax resident within the EU/EEA or in a jurisdiction with which Sweden has concluded a tax treaty, or the interest income is subject to at least 10% taxa tion in the hands of the beneficial owner of the interest if the in terest income is the only income of the beneficial owner.
Even if the above criteria are met, the interest expense is not taxdeductible if the debt relationship has been created “exclusively, or virtually exclusively,” to provide the group with a significant tax advantage.
The targeted interest limitation rules have been deemed incom patible with EU’s freedom of establishment. Therefore, the rules limiting tax deductibility on interest paid to foreign affiliated companies have been deemed inapplicable under certain circum stances.
Interest definition. The definition of interest in Swedish tax law includes “costs which are comparable to interest costs,” and in some cases, currency exchange rate effects.
Hybrid mismatches. Sweden introduced substantial additions to the Swedish provisions to counter hybrid mismatches as of 1 January 2020, applicable to affiliated companies or arrange ments resulting in a tax benefit.
Hybrid entities and instruments. A company is not allowed to deduct expenses paid to a company in another state if the corre sponding income is not subject to tax in that state and if this is due to differences in the classification of an entity (opaque/ transparent) or a financial instrument (debt/equity) for tax pur poses.
Imported mismatches. Deduction of a payment to an entity in a state outside of the EU is disallowed if the corresponding income from that payment is set off, directly or indirectly, against an ex pense that is giving rise to a deduction without inclusion or a double deduction.
Hybrid permanent establishments. A company is not allowed to deduct an expense paid to another company if the corresponding
income is not subject to tax and this difference is due to the one of the following:
• The recognition of a permanent establishment
• The allocation of income to a permanent establishment
• A deemed payment disregarded under the laws of the payee jurisdiction
Double deduction. A company is not allowed to deduct an expense if a deduction is also allowed against the income of a company in another state and if one of the following circum stances exists.
• The expense was attributed to a permanent establishment.
• The expense was paid by a Swedish company.
• This is due to a tax residency mismatch.
The application of the first and third circumstances described above is not restricted to affiliated companies or arrangements resulting in a tax benefit.
Limited foreign tax credit on hybrid-transfers. Deduction of foreign tax, attributable to income on a financial instrument, is disallowed to the extent the taxpayer receives a tax credit on dividend or interest income resulting from the terms of a transfer agreement of the financial instrument. The limitation applies only to the extent that another entity is granted a foreign tax credit for the same income and the dividend or interest income is part of a structured arrangement that generally entails a tax credit for the taxpayer and the taxpayer reasonably should have been expected to know about the arrangement.
Reverse hybrid mismatches. Sweden introduced further provi sions to counter hybrid mismatches on 1 July 2021. The provi sions extend tax liability on income from Swedish transparent entities to associated foreign entities if the income is not subject to tax in the state where the receiving entity is deemed to be a resident for tax purposes, as a result of the classification of the Swedish transparent entity in that state.
Mandatory disclosure regime. The EU directive on mandatory disclosure rules (DAC 6) requires intermediaries and taxpayers to disclose to the relevant tax authorities certain cross-border arrangements that contain one or more prescribed hallmarks. Some of the hallmarks trigger reporting requirements only if they also fulfill the main benefit test. From 1 January 2021, reporting is required within 30 days of certain trigger events.
F. Treaty withholding tax rates
Interest payments are not subject to withholding tax under Swedish internal law. Consequently, the table below provides treaty withholding tax rates for dividends and royalties only. However, under Swedish domestic law, no dividend withholding tax is levied on dividends paid by a Swedish company to a “foreign company,” as defined under Swedish tax law, if it is equivalent to a Swedish limited liability company and certain holding requirements are met. Also, no withholding tax is levied if the EU ParentSubsidiary Directive applies. In addition, a foreign legal entity qualifies as a “foreign company” if it is resident and liable to income tax in a jurisdiction with which Sweden has entered into
a comprehensive tax treaty and if it is eligible for the treaty ben efits.
Swedish domestic law on withholding tax contains an antiavoidance rule. Under this rule, a person or entity that holds shares to provide an illegitimate tax advantage or reduction of withholding tax for someone else is subject to withholding tax. The anti-avoidance rule may also potentially apply to situations for which an exception from withholding tax would otherwise be available.
Dividends Normal Reduced Residence of treaty rate rate (b)(d) Royalties (a) recipient % % %
Albania 15 5 5
Argentina 15 10 3/5/10/15 (g)
Armenia 15 5 (c) 5
Australia 15 10
Austria 10 5 0/10 (h)
Azerbaijan 15 5 5/10 (t)
Bangladesh 15 10 10
Barbados 15 5 5
Belarus 10 5 (c) 3/5/10 (j)
Belgium 15 5 0
Bolivia 15 0 15 (u)
Bosnia and Herzegovina (f) 15 5 0 Botswana 15 15
Brazil 25 (i) (i) 25 (i)
Bulgaria 10 5
Canada 15 5 (c) 0/10 (w)
Chile 10 5 (c) 5/10 (k)(u)
China Mainland 10 5 10
Croatia (f) 15 5 0
Cyprus 15 5 0
Czech Republic (e) 10 0 0/5 (l)
Denmark 15 0 0
Egypt 20 5 14
Estonia 15 5 5/10 (k)(u)
Faroe Islands 15 0 0
Finland 15 0 0
France 15 0 0
Gambia 15 5 (c) 5/12.5 (m)(u)
Georgia 10 0 0
Germany 15 0 0
Hungary 15 5 0
Iceland 15 0 0
India 10 10
Indonesia 15 10 10/15 (n)
Ireland 15 5 0
Israel 15 5 –/0 (o)
Italy 15 10 5
Jamaica 22.5 10 10
Japan 10 0 0
Kazakhstan 15 5 10
Kenya 25 15 20
Dividends Normal Reduced
Residence of treaty rate rate (b)(d) Royalties (a) recipient % % %
Korea (South) 15 10 10/15 (w)
Latvia 15 5 5/10 (k)(u)
Lithuania 15 5 5/10 (k)(u)
Luxembourg 15 0 0
Malaysia 15 0 8
Malta 15 0 0
Mauritius 15 0 0
Mexico 15 5 (c) 10
Montenegro (f) 15 5 0
Namibia 15 5 (c) 5/15 (m)
Netherlands 15 0 0
New Zealand 15 10
Nigeria 10 7.5 7.5
North Macedonia 15 0 0
Norway 15 0 0
Pakistan (q) 15 10
Philippines 15 10 15
Poland 15 5 5 Romania 10 10
Russian Federation 15 5 0
Saudi Arabia 10 5 5/7 (v)
Serbia (f) 15 5 0
Singapore 15 10 0
Slovak Republic (e) 10 0 0/5 (l)
Slovenia (f) 15 5 0
South Africa 15 5 (c) 0
Spain 15 10 10 Sri Lanka 15 10 Switzerland 15 0 0 Taiwan 10 10
Tanzania 25 15 20
Thailand 20 15 15
Trinidad and Tobago 20 10 –/0/20 (r)
Tunisia 20 15 5/15 (p)
Turkey 20 15 10
Ukraine 10 5 (c) 0/10 (m)
United Kingdom 5 0 0
United States 15 5 (c) 0
Venezuela 10 5 7/10 (s)
Vietnam 15 10 (c) 5/15 (m)
Zambia 15 5 10 Zimbabwe 20 15 10
Non-treaty jurisdictions 30 0
(a) Royalties paid to nonresidents are not subject to withholding tax but are taxed as Swedish-source income at the normal corporate tax rate. However, under certain treaties, the tax rate may be reduced.
(b) The reduced tax rate applies if the parent company owns at least the mini mum percentage of the paying company as prescribed by the relevant treaty. (c) The rate of tax is further reduced if specific conditions are satisfied.
(d) Under Swedish domestic law, dividends paid to a “foreign company” (as defined under Swedish law) are exempt from withholding tax if the shares are held for business purposes. Unlisted shares in Swedish companies are nor mally considered to be held for business purposes unless they are regarded as inventory. If the shares are listed, they must also be held for at least 12 months and the holding must amount to at least 10% of the voting rights. A special
exemption also applies if the recipient fulfills the conditions in Article 2 of the EU Parent-Subsidiary Directive and if the holding is at least 10% of the share capital.
(e) Sweden applies the treaty with the former Czechoslovakia to the Czech Republic and the Slovak Republic.
(f) Sweden applies the treaty with the former Yugoslavia to Bosnia and Herzegovina, Croatia, Montenegro, Serbia and Slovenia.
(g) The rates are 3% on news royalties, 5% for copyright (excluding films and certain other items) royalties, 10% for industrial royalties and 15% in other cases.
(h) The higher rate applies if the Austrian company owns more than 50% of the capital of the Swedish company. The EU Interest and Royalties Directive may be more beneficial in this respect.
(i) In practice, the domestic Swedish rate of 20.6% applies to all royalties because the treaty rate of 25%, which applies to trademarks, is higher than the domestic Swedish rate. For all other royalties, the treaty withholding tax rate of 15% has expired. Under a new tax treaty between Sweden and Brazil, the rates will be reduced to the following:
• Dividends: 15% normal treaty rate and 10% reduced rate
• Royalties: 15% rate for trademark royalties and 10% for all other royalties The rates will apply once Brazil has ratified the tax treaty and once the Swedish government has decided when the treaty should enter into force.
(j) The rates are 3% for patent royalties, 5% for leasing royalties and 10% for other royalties.
(k) The lower rate applies to leasing, and the higher rate applies to other royalties.
(l) The rates are 0% for copyright royalties and 5% for other royalties.
(m) The lower rate applies to industrial royalties.
(n) The lower rate applies to leasing and know-how royalties.
(o) The reduced treaty rate does not apply to mining royalties and cinemato graphic film royalties.
(p) The lower rate applies to copyright royalties.
(q) The domestic rate applies.
(r) The 0% rate applies to copyright royalties. The domestic rate applies to min ing royalties. The 20% rate applies to all other royalties.
(s) The 10% rate applies to copyright royalties.
(t) The 5% rate applies to royalties for the use of, or the right to use, patents, trademarks, designs or models, plans, secret formulas or processes, or for information concerning industrial, commercial or scientific experience. The 10% rate applies to all other royalties.
(u) The rate may be reduced by virtue of a most-favored-nation clause.
(v) The 5% rate applies to royalties for the use of, or the right to use, industrial, commercial or scientific equipment. The 7% rate applies to all other royal ties.
(w) The lower rate applies to copyright royalties, excluding royalties for films and certain other items.