DT18004 - Particular agreements: Sweden: Interest

Article 11(5) provides that interest paid by a United Kingdom company, in circumstances in which ICTA88/S209 (2)(e)(iv) and (v) would otherwise apply, is not to be treated as a distribution unless the Swedish recipient company is one in which more than 50 per cent of the voting power is controlled, directly or indirectly, by United Kingdom residents. But see DT215 for the position after FA 1995.