Sweden Tax Agency Explains Foreign Tax Settlement for Stock Transfer, Merger Between Life Insurance Companies

The Swedish Tax Agency May 16 issued Statement No. 8-2376631, explaining the foreign tax settlement for the stock transfer and merger between life insurance companies. The taxpayer, a Swedish life insurance company, sought to clarify whether it can set-off the foreign tax of a transferring company against the return tax on pension funds during a merger or transfer of an entire insurance portfolio between the life insurance companies. The tax agency clarified that the Swedish acquiring life insurance company is prohibited from offsetting the foreign tax paid by a Swedish transferring life insurance company against the return tax in the ...