QROPS Advice: Taxation of ‘Non-Residents’ Living in Sweden

A Swedish non-resident individual is subject to Swedish income tax only on income arising from sources in Sweden. Therefore expatriates regarded as non-resident individuals will only have a limited Swedish tax liability.
Non-residents will be subject to income taxes on remuneration arising from employment undertaken in Sweden and paid by a Swedish employer. Directors' fees paid by a Swedish company are always considered to have been earned in Sweden, regardless
of whether the activities are carried on in Sweden.
There is a specific concession available for non-resident expatriates working in Sweden. Non-residents may be taxed at a flat rate of 25% with no deductions applying. The 25% tax is withheld by the employer and is the final tax due on income. In order to benefit from the 25% flat rate (known as SINK) an application must be filed with the Local Tax Authority in advance, normally by the Swedish employer. There is normally no obligation to file an annual income tax return if you only have income from Sweden that is subject to a “SINK-ruling”. Non-residents working in Sweden and receiving the main part of their employment income from
Sweden may choose between being taxed according to the resident or non-resident rules, implying that certain deductions are available.
Non-resident individuals are generally not liable to pay capital income tax, though dividends received from a Swedish company are taxable unless tax exempt under a double taxation treaty. Non-residents are not generally liable to tax on gains of shares or on capital gains from the sale of personal assets. They will only be liable to tax on the gain resulting from the sale of real estate situated in Sweden and, where applicable, rental income from letting a home in Sweden (real property or flat).

full details go to http://www.ailo.org/common/externalPage.asp?intURL=/publications/default.asp&extURL=/downloads/Sweden_2009.pdf