Internationell beskattning av pensionsförsäkringar: – det svenska skattesystemet i gränsöverskridande situationer
2008 (Swedish)Doctoral thesis, monograph (Other academic)Alternative title
International Taxation of Pension Insurances : The Swedish Tax System in Cross-Border Situations (English)
The question at hand throughout this thesis is how the Swedish system for taxation of pension insurances – in both individual and occupational private pension schemes – interacts with other tax systems in an international context. This question includes several aspects. What are the outcomes when the Swedish system interacts with another Member State’s tax system in a cross-border situation? To what degree does the Swedish taxation of pension insurances live up to the underlying objectives of the system? Does the Swedish system constitute a restriction to free movement in the internal market for pension insurances? In order to be able to answer these and similar questions, a number of concrete situations that arise when the Swedish tax system meets a differently designed tax system of another Member State – Finland – are analysed. The Swedish taxation of pension insurances differs from that of a number of Member States as the Swedish system not only subjects the pension capital to a yield tax but also taxes the benefits upon disbursement to the beneficiary. In most other western European Member States – among them Finland – only the disbursed benefits are subjected to tax.
The results of the situation into the tax consequences in cross-border situations show that the Swedish system for taxation of pension insurances is not functioning in an international context. Sweden only manages to maintain the reciprocity within its tax system in a few of the analysed situations. The taxpayers are subjected to double taxation – sometimes even triple taxation – which is not eliminated by double taxation agreements or by regulations on credit-of-tax in national law. In the internal market for pension insurances, free movement is restricted and from a strictly national perspective, the underlying objectives of the Swedish system are not achieved.
Place, publisher, year, edition, pages
Norstedts Juridik AB , 2008. , 424 p.
international taxation of pension insurance, fiscal coherence, yield tax, mutual recognition
internationell beskattning av pensionsförsäkringar i Sverige och Finland, skattesystemets inre sammanhang, avkastningsskatt, kvalitativa villkor
Law (excluding Law and Society)
Research subject Financial Law
IdentifiersURN: urn:nbn:se:su:diva-7518ISBN: 978-91-39-01333-4OAI: oai:DiVA.org:su-7518DiVA: diva2:198479
2008-05-23, hörsal 8, hus D, Universitetsvägen 10, Stockholm, 10:15
Andersson, Edward, Professor emeritus
Silfverberg, Christer, ProfessorPersson Österman, Roger, Docent