Sweden: Non-UCITS foreign legal entities no longer eligible for tax exemption


Clearstream Banking1 would like to inform customers that, effective


foreign non-UCITS that are legal entities are no longer considered as equivalent to Swedish non-UCITS (special funds). Consequently, such foreign non-UCITS legal entities are no longer eligible for tax exemption on dividend distributions from Swedish equities.

This follows an announcement issued by the Swedish Tax Agency (STA), based on the interpretation of a recent court case (Rättsfallskommentar 2016-06-29, dnr 131 167163-16/111).

Impact on customers

The judgement affects only those non-UCITS that are legal entities, meaning that exemption at source is still available via Clearstream Banking for those foreign non-UCITS that are not legal entities, provided that the required documentation is provided to Clearstream Banking prior to the relevant deadlines.

Further information

For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.
1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500, and Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248.