This thesis treats the extended Swedish rules regarding deduction limitations on interest. The purpose for this thesis is to investigate whether the Interest deduction limitation rules have potential to protect the Swedish tax base. The thesis also assesses whether the options presented how the extended rules could look liked had been better to protect the Swedish tax base. Furthermore thin capitalizations rules have been evaluated if this is a better method to protect the Swedish tax base.In 2009 the Swedish deduction limitations rules on interest came in to force to protect the Swedish tax base. Despite these rules companies was still able to avoid Swedish tax and therefore threatened the Swedish tax base.

This thesis treats the extended Swedish rules regarding deduction limitations on interest. The purpose for this thesis is to investigate whether the Interest deduction limitation rules have potential to protect the Swedish tax base. The thesis also assesses whether the options presented how the extended rules could look liked had been better to protect the Swedish tax base. Furthermore thin capitalizations rules have been evaluated if this is a better method to protect the Swedish tax base.In 2009 the Swedish deduction limitations rules on interest came in to force to protect the Swedish tax base. Despite these rules companies was still able to avoid Swedish tax and therefore threatened the Swedish tax base.

Companies financed through borrowed capital are allowed a tax deduction for the costs re-lated to their borrowed capital. A similar tax relief for companies financed through share-holder?s equity does not exist, why these companies are taxed higher than companies fi-nanced by borrowed capital. The result is that there is an asymmetric tax treatment of companies depending on how they are financed.The autumn of 2012, the Swedish government presents a proposal for an investor deduc-tion which seeks to equalize the above mentioned asymmetry. The proposed investor de-duction is a tax relief for investments in shares in a startup- or small company equal to 50 percent of the acquisition cost of that investment.The venture capital deduction, which in this thesis is treated as an alternative to the inves-tor deduction, is an interest-free tax credit which significate that two-thirds of the acquisi-tion cost is deductible from taxation at the time of the acquisition.

In Sweden the main principle is that interest expenses are deductable. The rules of limitations on Interest deduction are exemptions to this main principle. The provisions, which came into force on the first of January 2009, have been inserted into Chapter 24 secs. 10 a ? e Swedish Income Tax Act (ITA).

The main purpose of our paper is to reconstruct the intervention logic of the Swedish government's proposal to introduce a tax deduction for homework help. Furthermore, we also intend to outline the perceived impacts of this tax deduction in the municipality of Linköping. Our material consists of the government bill regarding the tax deduction, the parliamentary debate which preceded it as well as interviews with key people in the municipality of Linköping. In our study and in the light of Matthew Clarke?s theory of neo-liberalism within education policy, we also ask ourselves if the intervention logic behind the tax deduction and its perceived effects can be seen as a manifestation of neo-liberalism.

The aim of this thesis was to study elderly people?s experiences of and approach to their usage of home care services with tax deduction. The aim was also to describe how elderly people reason about their underlying motives of using home care service with tax deduction. The study is based on six qualitative interviews with people between the ages of 65 and 80, living in Nacka, Sweden. This thesis is a collaboration with Stiftelsen Stockholms la?ns A?ldrecentrum/ Stockholm Gerontology Center and part of their follow up study concerning simplified administration for elderly people applying for home care services in Nacka.

On the 1st of January 2009, a new regulation regarding Interest deduction limitations was enforced. The aim was to prevent tax structure with Interest deductions in a community of interest. The changes meant that intra-group share transfers, which generates an intra-group loan structure, can lead to borrower losing their right to deduct interest expenses. Except from the main rule two exceptions were also introduced. These eliminates the limitations, and accept the deductibility despite the above conditions.

The aim of this thesis was to study elderly people?s experiences of and approach to their usage of home care services with tax deduction. The aim was also to describe how elderly people reason about their underlying motives of using home care service with tax deduction. The study is based on six qualitative interviews with people between the ages of 65 and 80, living in Nacka, Sweden. This thesis is a collaboration with Stiftelsen Stockholms la?ns A?ldrecentrum/ Stockholm Gerontology Center and part of their follow up study concerning simplified administration for elderly people applying for home care services in Nacka.

Interest deduction limitation rules have an important function as the regulations prevent the Swedish tax base to decrease. However, the restrictions must not be at the expense of the business environment. Interest deduction limitation rules that do not work in a satisfactory manner are likely to make Sweden a less favourable country to establish in. The first Swedish rules which were aimed to restrict Interest deduction threaded into force in 2009. The rules were applicable to intercompany loans related to acquisitions of part ownership rights and the aim was to reduce tax avoidance through corporate group-loans. The rules proved to be ineffective since the avoidance continued and the Swedish rules could not tackle the problem.

By means of group contributions the legislator has made it easier for company groups to transfer profits from a parent company to a subsidiary. A parent company can choose to reconstruct by acquire a company, create a subsidiary or perform a partial fission. The choice can affect the possibility for a parent company to perform a group contribution with deduction right.The parent company has to own more than 90 percent of the subsidiary?s shares for a whole taxation year or since the subsidiary began to carry out any economic activity in order to perform group contributions with deduction right. If a subsidiary is acquired, it has to be owned for a whole taxation year before group contributions with deduction right can be made, unless the acquired company never has carried out any economic activity before.

The Swedish group contribution rules do not include a right to deduction for cross-border group contributions unless the receiving company is taxable in Sweden. There has been much discussion regarding whether the rules are compatible with EC law. On 11 March 2009 the Swedish Supreme Administrative Court ruled ten cases concerning the right to deduction for cross-border group contributions. In three of these judgments deduction for a group contribution from a Swedish parent company to a foreign subsidiary within the EEA was allowed, despite that the subsidiary was not taxable in Sweden. The main purpose of this master thesis is to analyse whether the interpretation of the Supreme Administrative Court concerning the right to deduction for cross-border group contributions is compatible with EC law.

Till följd av att Skatteverket hade uppmärksammat problematiken med skatteplanering med ränteavdrag, så kallade räntesnurror, infördes de första svenska ränteavdragsbegränsningsreglerna för koncerninterna lån för företag i intressegemenskap år 2009. Dessa regler var inspirerade av motsvarande ränteavdragsbegränsningsregler i Nederländerna. På grund av att skatteplaneringen fortsatte, utvidgades de svenska ränteavdragsbegränsningsreglernas tillämpningsområde år 2013. Det har dock visat sig att på grund av nuvarande utformning och tillämpningsområde av 2013 års svenska regler, medför reglerna både tillämpningsproblem och fortsatt skatteplanering. Denna uppsats syftar till att undersöka utfallet av att införa liknande regler som nederländska ränteavdragsbegränsningsregler i Sverige, i nuvarande svenska ränteavdragsbegränsningsreglers ställe, för att analysera vilket av dessa regelverk som bäst uppfyller ändamålet med de svenska ränteavdragsbegränsningsreglerna.

The Swedish group contribution rules do not include a right to deduction for cross-border group contributions unless the receiving company is taxable in Sweden. There has been much discussion regarding whether the rules are compatible with EC law. On 11 March 2009 the Swedish Supreme Administrative Court ruled ten cases concerning the right to deduction for cross-border group contributions. In three of these judgments deduction for a group contribution from a Swedish parent company to a foreign subsidiary within the EEA was allowed, despite that the subsidiary was not taxable in Sweden. The main purpose of this master thesis is to analyse whether the interpretation of the Supreme Administrative Court concerning the right to deduction for cross-border group contributions is compatible with EC law.

In recent years, the possibility to deduct expenses for research and development (R&D) has been interpreted narrowly. As a response, the Income Tax Act chapter 16, section 9 (the R&D-rule) was amended to increase the possibility to deduct R&D of more general character. The purpose of this thesis is to determine the meaning of the R&D-rule to be able to decide if the amendment is an extension of the deductibility and whether this amendment can be considered adequate.According to the R&D-rule, the recipient of the grant needs to conduct R&D activity and there needs to be a sufficient connection between the R&D activity and the company to be allowed deduction. The difficulty in applying the R&D-rule is mainly when the research is conducted outside the company and the aim of the research is not to solve the company?s specific problem.The connection between the R&D-activity and the company needs to be reasonable. This means that only R&D-activity that falls completely outside the company?s activities should be excluded from deductibility.

Ända sedan införandet av de svenska ränteavdragsbegränsningarna, som kan leda till nekat avdrag för räntekostnader inom intressegemenskapen beroende på mottagarens skattesituation och syftet bakom transaktionen, har reglernas förenlighet med EU-rättens etableringsfrihet varit ett omdiskuterat ämne. Syf-tet med denna uppsats är att utröna reglernas förenlighet med EU-rätten på denna grund.EU-rätten förbjuder vanligtvis alla former av hinder mot etableringsfriheten. Avsteg får dock göras i särskilda fall om hindrande åtgärder kan motiveras mot bakgrund av art. 52(1) FEUF eller ett trängande allmänintresse. De hindrande åtgärderna måste vidare ha till syfte att uppnå de anförda rättfärdigandegrun-derna samt inte gå utöver vad som är nödvändigt för att uppnå dess mål.EU-kommissionen menar att reglerna särskilt missgynnar gränsöverskridande verksamhet.