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Sweden vs “CA AB”: JUDGMENT

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Sweden vs “CA AB”: JUDGMENT

Case Information

  • Court: The Supreme Administrative Court (Sweden)
  • Case No: 1348-24 1349-24
  • Applicant: [Company Name Redacted] AB
  • Defendant: Swedish Tax Agency
  • Judgment Date: 25 November 2024

The case at hand concerns a dispute under the Nordic Tax Convention, a treaty aimed at avoiding double taxation among its signatories. The applicant, [Company Name Redacted] AB, received interest income from a related Norwegian entity in 2011 and 2012, which was taxed in Sweden. Concurrently, the Norwegian tax authority disallowed the corresponding deduction for interest expenses, citing non-compliance with the arm’s length principle. This discrepancy led to double taxation.

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Categories: Sweden
Tags: Advanced Pricing Agreements, ALP, APAs, Arms Length Principle, International Tax, Mutual Agreement Procedure, Tax Compliance, Transfer Pricing
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Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
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5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected