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Sweden: Proposed increase to property tax for wind turbines; deductions for fictitious tax under income tax treaty with Luxembourg

Government proposal; tax agency statement

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March 7, 2025

The Swedish government on January 21, 2025, proposed an increase in the property tax for wind turbines. The standard property tax rate for electricity production units is 0.5% of the assessed value, while wind turbines currently have a rate of 0.2% or 0.5%. If the proposal is accepted, the tax rate for wind turbines will increase to the standard rate of 0.5%, taking effect from January 1, 2026.

For more information, contact a 乐鱼(Leyu)体育官网 tax professional in Sweden:

Rebaz Wahab | rebaz.wahab@kpmg.se

Deductions for fictitious tax

Sweden's tax agency on January 13, 2025, disputed a decision by the Administrative Court of Appeal in J枚nk枚ping concerning whether a Swedish company should be granted a foreign tax credit for a fictitious tax related to a business transfer from a branch in Luxembourg to company in Luxembourg. The Administrative Court of Appeal held that the profit and fictitious tax credit should be calculated on the difference between the value of the intangible assets at time of transfer to the Luxembourg company and the initial value. The tax agency considered the decision incorrect and appealed, but the Supreme Administrative Court declined to hear the case.

The tax agency argued that the tax treaty between Sweden and Luxembourg would not result in a taxable gain in Luxembourg since, according to the tax treaty, any profit would be calculated on the difference between the market value of the intangible assets when transferred to the Luxembourg company and the market value at the transfer from the Swedish company to the branch, and cites a previous verdict by the Administrative Court of Appeal in Stockholm in a similar case as support for its interpretation.

For more information, contact a 乐鱼(Leyu)体育官网 tax professional in Sweden:

Helene af Sandeberg | helene.af.sandeberg@kpmg.se

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