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Tax agency clarifies call-off warehouse transfers and fixed establishment

  • The Swedish Tax Agency has released a statement (No. 8-2418494) clarifying the rules for establishing a fixed establishment for sellers who transfer goods to call-off warehouses in Sweden.
  • The statement outlines that for simplification rules to apply, the seller must not have a registered office or fixed establishment in the EU country where the goods are transported.
  • The Tax Agency considers a warehouse owned or rented by the seller, operated directly by the seller or through hired staff or another company on the seller’s behalf, to constitute a permanent establishment.
  • However, a warehouse not owned or rented by the seller and operated directly or indirectly by someone else is not considered a permanent establishment.
  • This statement replaces the previous position statement and aligns with the VAT Committee’s guidelines and the amended sections of the new VAT Act, taking effect from July 1, 2023.

Source GVC


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