- The Swedish Tax Agency (Skatteverket) considers the sale of shelf companies (lagerbolag) or dormant companies (historikbolag) to be a single transaction involving the sale of shares or participations. This means that previous legal precedents from RÅ 2009 not. 175 and HFD 2011 not. 33 are no longer applicable.Shelf companies are newly formed and registered with the Swedish Companies Registration Office (Bolagsverket), while dormant companies are liquidated but still have tax registrations and other documents.The central question is whether the sale of shares and participations in these types of companies should be treated as a single transaction.According to the Value Added Tax Act (mervärdesskattelagen) and EU directives, services provided for payment are subject to VAT. For a service to be considered to have occurred, there must be a direct link between the service and the payment.The Supreme Administrative Court (Högsta förvaltningsdomstolen) has established that closely related transactions can be regarded as a single transaction. A service is considered subordinate if it serves only as a means of enjoying a principal service.
Source: www4.skatteverket.se
Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.
