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).

Title: Dormant companies ? Taxation of closely held companiesProblem: Many companies are facing a business transfer and fall within a smaller company with a few owners and therefore that tax jurisdiction is current. They risk facing high taxes but it can be avoid by setting the company in an inactive status for five years.Purpose: The purpose is to describe the inactive company rules and the verdict from the Swedish Supreme Administrative Court. Also to investigate how this verdict will affect company sellers.Method: Based on a case study and by analyzing the Swedish Law conclusions has been determinate.Result: A dormant company must be inactive for five years, and then the company can benefit from a different taxation. The owner and it´s relatives can´t be active in the company during this five year period.

States have sovereignty in deciding how to tax business profits. If two states wish to tax the same profit that belongs to the same taxpayer, double taxation will arise. The increasing number of multinational companies gives rise to double taxation problems and the states have to co-operate to find out how to avoid such problems. The OECD Model Tax Convention includes an article in how to determine the rights to tax business profits. This article has been a subject of discussion and a committee of the OECD has been working to develop a new article 7.The work in proposing this new article has had as its aim to reassure that the interpretations of this regulation is made in the same way.

The connection between accounting and taxation goes back to the 1920s laws of the named areas. A proposal has now been brought forward, the so-called SamRoB-investigation, which means that the connection between accounting and taxations should be decoupled.The authors? aim with the study is to investigate what a possible decoupling between accounting and taxation, i.e. the formal connection and the untaxed revenues, implicates for the auditor´s work.A research has been done by interviewing two authorized auditors and one authorized consultant of accounting to get a view in how the auditor?s works could be affected.

This thesis analyzes the consequences of ?Lex Uggla? ? a law concerning the boundaries between firm and individual with respect to wealth taxation ? for small businesses, with more than 3 million SEK in over-liquidity. There are two main findings of this thesis. Firstly, the wealth taxation of non-operational assets seems to be an inefficient tax which costs the Swedish welfare system much more than it generates. Secondly, the change in actions among entrepreneurs following the extensive news coverage following the tax authority?s charges against the company of the well-known artist, Magnus Uggla (hence ?Lex Uggla?) illustrates that neither changes of rules nor new applications of rules is necessarily sufficient for an agent to change course of action.

On the 26th of January 2010, the Supreme Administrative Court in Sweden gave five rulings which greatly affect the possibility to keep a close company within a family by transferring the ownership of the company to the next generation. The five rulings concern the interpretation of the prerequisite, same or similar activity, which can be found in section 57, clause 4 of the Swedish Income Tax Act.    The prerequisite is fulfilled when an entire or parts of a business is transferred to another close company and the receiving company?s business activity is within the framework of the transferring company?s business activity or when the companies have a similar connection. Depending on which shares that are being evaluated, the prerequisite can refer to both the shares in the receiving or the transferring company. When the prerequisite is fulfilled, a standardized amount of the business income will be taxed as capital gains and the surplus will be taxed as earned income.

In 2007 the Swedish government appointed a commission of inquiry with the task to submit a proposal of reduction in the requirement of a minimum legal capital for private limited liability companies. The commission of inquiry?s main proposal involved a reduction to SEK 50,000 compared to the prevailing SEK 100,000. Following a complementary proposal from the Justice Department suggesting a reduction to SEK 1, this paper aims at providing an understanding of the function and purpose of a minimum legal capital and the consequences that follows from an abolition of the statutory capital requirement. The thesis concludes that the legal capital?s main purpose is that of a standard contract internalizing the shareholder?s risk in business.

There exist a number of different types of value transfers between companies in a group. Most of these transfers are undertaken on the basis of private law. These transfers also give rise to tax law consequences. Taxation is normally based on how the classifications of transfers are made in private law, which means that there exists a relation between private law and tax law. Despite this relation, the classification is not always made in the same way in private law and tax law.

AbstractThis bachelor thesis deals with the close company rules in chapter 56-57 within the Swedish income tax law (IL). The purpose of this thesis is to analyse the outsider rule in 57:5 IL. If a shareholder or a family member works or have worked actively within the company within the fiscal year or the last five fiscal years then the partner has qualified shares and is to be taxed according to the special closed company rules.If an outsider, directly or indirectly, is a significant shareholder within the company, and directly or indirectly, are entitled to dividends then an active partner only has qualified shares if there is special reasons. When making the assessment regard must be made to conditions under the fiscal year or the last five fiscal years. There is special reason not to apply the rule if there are agreements regarding how the profit should be split or cross-ownerships between companies.If a taxpayer can show that an outsider own 30 percent of the closed company and has a right to dividends and there is no special reason to why the rule should not be applied then the outsider rule is applicable.

Nyckelord: CSR, SRI, Shareholder Value och Etiska placeringar Problemformulering: Hur ser förvaltarna och investerarna på framtiden för CSR/SRI och kommer deras jobb som förvaltare och investerare att förändras efter kriserna som varit? Syfte: Syftet med studien är att undersöka hur CSR och SRI har och kommer att utvecklas på den svenska investeringsmarknaden.Metod: För att besvara studiens syfte och frågeställning valdes en kvalitativ ansats. I uppsatsen intervjuas investerare som arbetar dagligen med CSR/SRI investeringar. I uppsatsen används artiklar inom området för socialt hållbara investeringar. De svar som erhålls av respondenterna i intervjuerna granskas, reflekteras samt jämförs med tillgänglig forskning på området.

The VAT Directive (2006/112/EC) does not regulate Member States? opportunities to intervene against tax evasion. The European Court of Justice has clarified the situation in case C-255/02 Halifax. This case establish that the universal principle against the abuse of rights applies to VAT, which means that Member States have the opportunity to redefine transactions not involving a breach of law but nevertheless goes past what the legislature envisaged at the introduction of the provision.A debate has risen as to whether the principle against the abuse of rights is equally ap-plicable in Swedish domestic law on VAT. The administrative court of appeal in Go-thenburg, Case No.

The connection between accounting and taxation goes back to the 1920s laws of the named areas. A proposal has now been brought forward, the so-called SamRoB-investigation, which means that the connection between accounting and taxations should be decoupled.The authors? aim with the study is to investigate what a possible decoupling between accounting and taxation, i.e. the formal connection and the untaxed revenues, implicates for the auditor´s work.A research has been done by interviewing two authorized auditors and one authorized consultant of accounting to get a view in how the auditor?s works could be affected.

The Swedish tax on income for persons who are unlimited liable to tax is based on his domicile and double taxation treaties between Sweden and other countries are based on his residence. In order to determine a person?s tax liability, the dwelling or home is of vital importance to determine where a person has his domicile and residence.For a person who has moved from Sweden, to be unlimited tax liable here, there must be an essential link. This link can be through previous residence in Sweden, the person is not a permanent residence in a foreign country, in possession of housing for year-around-use or in possession of house property.Sweden has concluded double tax agreements with other countries for the reason to prevent double taxation on the same income. When a taxpayer may be regarded as a resident in two states, the situation must be resolved to avoid that double taxation will arise.

The taxation of various kinds of income which Sweden requires taxpayers to pay results in people undertaking sophisticated tax schemes to avoid paying tax . As a result of this Sweden had to develop its tax laws and insert a general clause in the legislation because the legislator wanted a more preventive effect. This preventive effect results in that the clause is applicable to more various types of tax situations. The clause, found in § 2 law (1995:575) against tax treaty override, states four requisites that must be met for a procedure to be considered tax treaty override. The relevant point for this paper is the fourth item which created interpretation problems among courts.

1998 års företagsskatteutredning föreslår i SOU 2001:11 att beskattningen av kapitalvinster på företagsägda näringsandelar (BKN) avskaffas. Denna uppsats behandlar frågan om hur ett sådant avskaffande skulle påverka de s.k. fåmansföretagsreglerna i IL 57 kap. I uppsatsen visar jag att de nuvarande reglerna i IL 57 kap. inte skulle förmå uppfylla deras syfte vid ett eventuellt avskaffande av BKN.