Sweden: SICAV-SIF’s ruled non-equivalent to Swedish special funds
The Swedish Supreme Administrative Court issued a ruling, on 18 March 2016, stating that a Luxembourgish SICAV-SIF cannot be considered as equivalent to a Swedish special fund in regards to the Swedish provisions on the standard income taxation for the holding of shares in fund units.
As a result of the Swedish Supreme Administrative Court’s ruling there is the possibility that this may impact all non-resident funds that are legal entities, and not only Luxembourgish SICAV-SIFs. Furthermore, it is expected that the ruling may also be applicable to withholding tax on dividends, where non-resident funds that are legal entities (and non-UCITS) are currently eligible for withholding tax exemption, if they fulfil certain conditions.
We continue to monitor the Swedish market and will provide further information as it becomes available.
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