Sweden: Dividend withholding tax for investment funds abolished

Further to our Announcements (A11096, dated 8 July 2011, and A11120, dated 31 August 2011) and Taxflash (T11085, dated 27 December 2011), and effective

1 January 2012

the withholding tax on Swedish sourced dividends is abolished for foreign investment funds which qualify as "fund undertakings" (fondföretag), as defined in the Swedish Investment Funds Act (lag om investeringsfonder), and that are either domiciled:

i) within the EEA;

ii) in a state with which Sweden has entered into a tax treaty which contains an article on exchange of information; or

iii) in a state with which Sweden has entered into an agreement on the exchange of information in tax matters.

According to a statement of the Swedish Tax Agency the following fund undertakings domiciled in a state mentioned above are exempt from Swedish withholding tax on dividends.

1. Funds established in accordance with the UCITS directive (2009/65/EG), and

2. Non-UCITS funds which are authorised by the Swedish Financial Supervisory Authority to market and sell units in the fund in Sweden.

The Swedish Tax Agency will inform if more funds, in addition to those mentioned above, may be tax exempt.

Impact on customers

From 1 January 2012 Swedish investment funds and certain foreign investment funds will be eligible for full exemption from withholding tax on dividend distributions from Swedish equities.

Note: The Swedish Tax Agency will provide further information concerning the procedure and the document requirements either for tax relief at source (if it will be available) and normal reclaims.

We will continue to monitor the situation for any new developments and will provide more information as it becomes available.

Further information

For further information, please contact the Clearstream Banking¹ Tax Help Desk on:

or Clearstream Banking Customer Service or your Relationship Officer.

1. Clearstream Banking refers collectively to Clearstream Banking AG, registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in the Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500 (CBF) and Clearstream Banking, société anonyme, registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Register of Commerce and Companies under number B-9248 (CBL).