This article aims to give an overview of the rules concerning taxation of companies in Sweden and of trends in the taxation of companies that have been evident in the last few years. It focuses in particular on issues that are connected with the so-called BEPS discussion, for instance interest deduction limitations, CFC rules, general anti-avoidance rules and other rules intended to protect the national tax base. It also sets out to describe other important features of the Swedish tax legislation in regard to companies, such as the rules on taxation of inbound and outbound dividends, interest and royalty.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI), which was signed in June 2017, raises a multitude of questions relating not only to the text of the treaty provisions but also to the way the MLI will interact with tax treaties, for instance, and what it will mean for the future development of tax treaty law and international cooperation in tax matters. This article focuses on two aspects of the MLI. First, it deals with the substance of the MLI by providing an overview of its background and content, including the many options available to the contracting states under the MLI. Second, some thoughts are presented on the effects of the MLI in terms of complexity and uncertainty.