On 24 June 2026, Sweden and the Netherlands signed a new tax treaty, which will replace the current treaty from 1991 once it enters into force. The treaty aims to prevent double taxation and tax avoidance and modernise the rules in line with the current OECD Model Tax Convention.
Although the treaty is not yet effective, it introduces several changes that may affect individuals and companies with connections to Sweden and the Netherlands. We have asked our SME-member Skeppsbron Skatt to explain the changes to our members:
Key Changes
Pensions may be taxed in the source country
One of the most significant changes concerns pensions. Under the new treaty, pensions and similar payments may also be taxed in the country where the pension rights were earned. (except from pensions from the social security system which are already today taxed in country of source).
This means that, for example, a person resident in Sweden who receives Dutch occupational pension, going forward will be taxed in both countries but Sweden will offer a relief to avoid double taxation. Given that Sweden has a higher marginal tax rates than the Netherlands, this may imply a higher tax burden going forward.
Extended taxing rights after emigration
The new treaty also extends the period during which the so-called ten-year rule is applicable. A state may continue to tax capital gains on shares and similar assets after an individual has moved abroad. The period is expected to increase from five years up to ten calendar years, after the move has taken place.
For individuals moving between Sweden and the Netherlands, the timing of both emigration and any subsequent disposal may therefore become more important.
Reduced ownership threshold for dividends
For dividends between companies, the ownership threshold for avoiding withholding tax is reduced from 25 percent to 10 percent, provided that the certain conditions are met.
Rules on board members are expanded
The rules on taxation of board fees in residency as well as source state are also expanded to cover persons in general management positions.
Skeppsbron Skatt’s comments
The new treaty reflects a broader modernisation of Sweden’s tax treaty network and may have practical implications for both private individuals and corporate groups. While the timing of entry into force remains to be confirmed, affected taxpayers should consider the potential impact of the new rules when planning future cross-border arrangements. Although the entry into force is still pending, the changes indicate how taxing rights between the two countries are expected to be allocated going forward.
If you have any questions about what impact the changes may have in your case, you are more than welcome to contact us at Skeppsbron Skatt. We have extensive experience assisting both companies and private individuals with matters relating to international taxation and Swedish tax liability.
Although the treaty is not yet effective, it introduces several changes that may affect individuals and companies with connections to Sweden and the Netherlands. We have asked our SME-member Skeppsbron Skatt to explain the changes to our members:
Key Changes
Pensions may be taxed in the source country
One of the most significant changes concerns pensions. Under the new treaty, pensions and similar payments may also be taxed in the country where the pension rights were earned. (except from pensions from the social security system which are already today taxed in country of source).
This means that, for example, a person resident in Sweden who receives Dutch occupational pension, going forward will be taxed in both countries but Sweden will offer a relief to avoid double taxation. Given that Sweden has a higher marginal tax rates than the Netherlands, this may imply a higher tax burden going forward.
Extended taxing rights after emigration
The new treaty also extends the period during which the so-called ten-year rule is applicable. A state may continue to tax capital gains on shares and similar assets after an individual has moved abroad. The period is expected to increase from five years up to ten calendar years, after the move has taken place.
For individuals moving between Sweden and the Netherlands, the timing of both emigration and any subsequent disposal may therefore become more important.
Reduced ownership threshold for dividends
For dividends between companies, the ownership threshold for avoiding withholding tax is reduced from 25 percent to 10 percent, provided that the certain conditions are met.
Rules on board members are expanded
The rules on taxation of board fees in residency as well as source state are also expanded to cover persons in general management positions.
Skeppsbron Skatt’s comments
The new treaty reflects a broader modernisation of Sweden’s tax treaty network and may have practical implications for both private individuals and corporate groups. While the timing of entry into force remains to be confirmed, affected taxpayers should consider the potential impact of the new rules when planning future cross-border arrangements. Although the entry into force is still pending, the changes indicate how taxing rights between the two countries are expected to be allocated going forward.
If you have any questions about what impact the changes may have in your case, you are more than welcome to contact us at Skeppsbron Skatt. We have extensive experience assisting both companies and private individuals with matters relating to international taxation and Swedish tax liability.
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