Sweden has 81 tax agreements, as reported in its response to the Peer Review questionnaire, including the multilateral Nordic Convention concluded with Denmark, the Faroe Islands, Finland, Iceland and Norway (the “Nordic Convention”).1 Two of those agreements, the agreement with Russia and the Nordic Convention, comply with the minimum standard.

Sweden signed the MLI in 2017 and deposited its instrument of ratification on 22 June 2018. The MLI entered into force for Sweden on 1 October 2018. Sweden has not listed its agreements with Australia, Austria, Bosnia-Herzegovina, Brazil, Croatia, France, Germany, Montenegro, Portugal, Serbia, Singapore, Slovenia, Spain and Switzerland but indicated in its response to the Peer Review questionnaire that bilateral negotiations would be pursued with respect to its agreements with Brazil, Germany, Portugal Singapore, Slovenia, Spain and Switzerland. Australia, Bosnia-Herzegovina, Croatia, France, Portugal, Serbia and Singapore have listed their agreements with Sweden under the MLI.

The Parties to the Nordic Convention signed a complying instrument in 2018. The protocol entered into force on 28 November 2019 and its provisions took effect on 1 January 2020.

Sweden is implementing the minimum standard through the inclusion of the preamble statement and the PPT.2

The agreements that will be modified by the MLI will come into compliance with the minimum standard once the provisions of the MLI take effect.

Sweden has made a reservation under the MLI that delays its entry into effect after completing its internal procedures for this purpose for each of its listed agreements.3 Sweden has not yet notified that it had completed its internal procedures for any of its listed agreements.

As mentioned above, Sweden has not listed its agreements with Australia, Austria, Bosnia-Herzegovina, Croatia, France, Montenegro and Serbia under the MLI. Listing the agreements under the MLI or entering into bilateral renegotiations to implement the minimum standard would ensure that the minimum standard could be implemented in those non-covered agreements.


← 1. See the Multilateral convention concluded by Denmark, Finland, the Faroe Islands, Iceland, Norway and Sweden: for the avoidance of double taxation with respect to taxes on income and on capital (1996, 1997, 2008 and 2018). In total, Sweden identified 85 "agreements" in its List of Tax agreements: 80 bilateral agreements and the Nordic Convention concluded with five of its treaty partners.

← 2. For its agreements listed under the MLI, Sweden is implementing the preamble statement (Article 6 of the MLI) and the PPT (Article 7 of the MLI).

← 3. The reservation was made under Article 35(7)(a) of the MLI.

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