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Through the rulings RÅ 2010 ref. 11, HFD 2011 ref. 75 and HFD 2011 not 88 the Swedish Supreme Administrative Court have extended the concept of same or similar activities which can be found in section 57, clause 4 of the Swedish Income Tax Act. Through the ruling the Court has partly clarified the application area of the regulation but question marks still remains.In the statutory text there is no definition of what shall be regarded as same or similar activity and the preparatory work does not give any further direction on how the concept should be interpreted. Ever since the amendment in 1995 the general view has been that activities can be transferred between different companies without affecting the waiting period in the company of origin. This view have changed through the Swedish Supreme Administrative Courts latest ruling which may result in great tax consequences for partners that own so called passive asset management company in order to be able to retrieve capital from the company after five years, taxed as capital gains.The regulation essentially becomes applicable when the entire or part 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. It is sufficient that the activity consist of capital management in order for the regulation to be applicable. How the capital is transferred between the companies is not of importance. The capital can be transferred both as bonus allocation and purchase price.The Swedish Supreme Administrative Court has also opened up the possibility to deskill shares through a so called ?double insider?. The question has been raised if the double insider will fall within the application area of the Swedish Tax Avoidance Law but the uncertainty still remains.