Sweden Tax Court Issues Advance Notice Clarifying Significant Connection Rules for Tax Residency Determinations

The Swedish Tax Court Nov. 19 issued Advance Notice No. 35-25/D, clarifying significant connection rules for tax residency determinations. The taxpayer, a Swedish citizen who moved abroad from Sweden in 2007, intended to carry out various transactions in 2025, including receiving 50 percent of a holiday home in Sweden as a gift from his brother, as well as obtaining all the shares from his father in a nonresident company (X AG), which owned 40 percent of another nonresident company (Y AG), where Y AG would form a Swedish subsidiary. The taxpayer sought clarification on whether he would have a substantial ...