Swedish interest deduction limitation rules for intra group debt

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The Swedish supreme administrative court has requested a preliminary ruling from the court of Justice of the European Union (CJEU) in relation to the Swedish interest deduction limitation rules for intra group debt

The Swedish Supreme Administrative Court has on 5 June 2019, in relation to the interest deduction limitation rules from 2013, requested a preliminary ruling from CJEU on whether it is compatible with the freedom of establishment within EU to refuse a Swedish company deduction for interest paid to a French group company which is a member of a French tax group with losses carry forwards.

The Swedish rules in question have been criticized for not being compatible with EU law (including the rules from 2009), and a formal infringement procedure against Sweden has been initiated by the European Commission.

Authored By:
Magnus Larsén

Henrik Kjellgren