DT18059 - DT: Sweden: double taxation agreement, Article 10:

DT18059 - DT: Sweden: double taxation agreement, Article 10:

Postby richiwatts on Wed Jan 25, 2012 4:33 pm

I found this on HMRC

(1) Dividends derived from a company which is a resident of Sweden by a resident of the United Kingdom shall be taxable only in the United Kingdom if the beneficial owner is a resident of the United Kingdom and is a company which controls directly or indirectly at least 10 per cent of the voting power in the company paying the dividends. In all other cases, dividends derived from a company which is a resident of Sweden by a resident of the United Kingdom may also be taxed in Sweden according to the laws of Sweden but, provided that the beneficial owner is a resident of the United Kingdom, the tax so charged shall not exceed 5 per cent.

Sweden's tax year Jan-Dec
UK tax year April-March

In June 2010 I moved to the UK from Sweden. I left my company in Sweden and asssigned a Manger to run things for me.
In February 2011, I paid myself a dividend of 50,000 SEK (This is gross amount and I will have to deduct and pay tax in June in Sweden had I still lived there).

If I have understood the article above correctly, I am liable to pay tax on the dividend in UK not Sweden?
But I will also need to pay up to 5% of the tax due or above what is due in the UK to the Swedish tax office?

Or is it the other way around? Maybe I have totally misunderstood?
richiwatts
 
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Re: DT18059 - DT: Sweden: double taxation agreement, Article 10:

Postby section 44 on Thu Jan 26, 2012 3:23 pm

you appear to have understood it
section 44
 
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Re: DT18059 - DT: Sweden: double taxation agreement, Article 10:

Postby maths on Thu Jan 26, 2012 4:09 pm

If I have understood the article above correctly, I am liable to pay tax on the dividend in UK not Sweden?
But I will also need to pay up to 5% of the tax due or above what is due in the UK to the Swedish tax office?


Not sure this is correct.

The Article provides for the primary liability to arise within the UK due to your UK residency.

However, Sweden retains the right to levy up to 5% of its own tax.

EG
100 gross div paid.
Sweden levies 5% ie 5.
You receive 95 cash.

In UK liability at 42.5% or 32.5% on 100 less a credit for 5.

Apologies if this is what you meant.
maths
 
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