Strategizing Multinational Tax Risks

The Swedish tax authorities have adopted the anti-hybrid legislation of the EU Parent Subsidiary Directive (PSD), and have chosen to expand the participation exemption limitation to non-EU countries.

A link to EY’s Tax Alert discusses the details of this recent development.

Click to access 2015G_CM5392_Swedish%20Gov%20proposes%20limitation%20to%20participation%20exemption%20rules%20and%20amendments%20to%20Swedish%20Tax%20Avoidance%20Act.pdf

The opportunity to reach beyond the EU PSD, incentivized by OECD BEPS draft actions, may become more a norm than the exception, and is a trend worth watching.