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Abstract

By the late 1960s, real effective taxation of income from individual firm ownership in Sweden approached 100 percent. A series of tax reforms has reversed this situation. This paper (1) elucidates the thinking behind the vision of creating a largely market-based system without wealthy capitalists and how that vision guided tax policy; (2) outlines and evaluates the changes in the tax code since the late 1970s, their empirical and intellectual basis, and their implications for the taxation of individual firm ownership; and (3) compares the size of the largest individual wealth holdings in the mid-1960s to their equivalents in the 2010s and discusses how the general public’s views have changed regarding sizeable income streams and wealth from business activity. Today, the tax code favors already wealthy individuals, while high labor income taxation combined with a high valuation of existing assets renders wealth accumulation difficult for persons with no initial wealth.

Abstract

Value-added tax (VAT) grouping schemes, whereby several legally independent entities are treated as a single taxable person for VAT purposes, are well known, though their detailed rules differ from country to country. This article deals with specific tax avoidance and fiscal competition aspects of VAT grouping schemes in Denmark, Norway, and Sweden. The article gives examples of tax abuse and avoidance by using various VAT grouping models, with the main emphasis on the practice in Denmark, which may be indicative of similar problems in other countries. The article shows that there are significant differences in the rationales for national VAT grouping schemes, and these indicate that there are mismatches between the national schemes of the EU Member States and the original intention of the EU scheme. Finally, an examination of the different national rationales shows the necessity of striking a balance between combating tax avoidance and preventing distortion of competition.

Abstract

This section contains reviews of two Swedish books on international taxation. First, the book Skatteavtal och generalklausuler, Ett komparativt perspektiv (Tax Agreements and General Anti-Avoidance Regulations, A Comparative Perspective) is recommended for those who study and work with international tax law. The book analyses how tax treaties’ function to limit contracting states’ taxing powers relates to national GAARs. A comparative analysis is made between Sweden and Canada. In the second review, the doctoral dissertation EU-domstolens restirktionsprövning i mal om de grundläggande frihterna och direkta skatter (The EU Court of Justice’s examination of the restriction requirement in its direct tax case law) is reviewed. The dissertation systemizes relevant CJEU’s case law and analyzes the Courts reasoning in deciding whether or not certain tax regulation is in conflict with EU fundamental freedoms.

Abstract

The Swedish Tax Agency is responsible for controlling as well as informing and assisting the taxpayers. Even if these tasks are not necessarily contradictory, they can be difficult to perform all at once. In their performance of duties, tax agency employees have to meet the expectations of the management as well as of the taxpayers. The goal fulfilment of the Tax Agency is contingent on the organisation’s ability to provide a stress-free working environment. Stress may cause physical and psychological problems.

Abstract

Recently, the controlled foreign company (CFC) rules have gained increased attention; as such, rules play an important role in the ongoing efforts of the OECD/G20 and the European Commission with respect to addressing base erosion and profit shifting (BEPS). In this context, the article revisits the CFC regimes of the Nordic countries in order to assess whether these regimes are in line with the recommendations from the OECD/G20 and to determine whether Sweden, Finland, and Denmark, as EU member states, will have to make amendments if the commission’s proposal for an Anti-Tax Avoidance Directive is adopted in its current form. It is concluded that the Nordic CFC regimes in many ways already are in line with the recommendations as well as the directive, but also that certain amendments have to be made.