Sweden Tax Court Issues Advance Notice Clarifying Service Individual Income Tax Exemption

The Swedish Tax Court Dec. 9, 2025, issued Advance Notice No. 103-24/D, clarifying the service individual income tax exemption. The taxpayer, a company’s senior employee, would receive all the company owner’s shares in the company in a restructuring after his death. The taxpayer sought clarification on whether the transfer of shares to a new company, which would increase her shares’ value, would constitute a transfer at a lower price. Upon review, the Tax Court found that: 1) the exemption applied because the transfer would occur without compensation or for remuneration below market value without commercial justification; 2) the exemption also ...