DT18003 - Particular agreements: Sweden: Dividends

For dividends paid on or after 1 January 1979, the Swedish tax on dividends (Kupongsskatt) is limited to 5 per cent (nil if the beneficial owner is a United Kingdom company controlling, directly or indirectly, at least 10 per cent of the voting power in the Swedish company) (Article 10(1)). The above reductions are not given where the dividends are effectively connected with (see DT214 fifth sub-paragraph) a permanent establishment or fixed base which the United Kingdom resident recipient has in Sweden. This tax qualifies for credit as a direct tax (see DT950(c)).

Where a dividend is paid to a United Kingdom company which controls, directly or indirectly, not less than one-tenth of the voting power in the Swedish company, credit is also due for the underlying tax (see DT950(d)) (Article 22(1)(b)).

See DT956 for information on relief for Swedish tax where dividends are paid on or after 1 January 1995 to a company resident in the United Kingdom which holds at least 25 per cent of the capital of the company paying the dividend.