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IT Assurance
Digital information management requires great security, both in terms of protection against intrusion and against loss of data. Our experts will help you find an optimized solution adapted to the company's information management.
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Virtually every transaction in a company needs VAT management. The rules may seem complicated, and improper handling of the VAT can cause unnecessary costs and penalties for your business.
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Sustainability services
The world's demands the performance on companies' are increasing, not only financially, but also environmentally and socially. It is the company's' total responsibility and the function they fulfill in society that counts.
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Integration & Separation
We support our customers throughout the entire process, from defining separation alternatives and understanding the potential impact on value creation, to developing and delivering robust separation plans.
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Internal audit
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In connection with acquisitions, our transaction advisory team helps you through the entire process: from advisory and pre-bid support, reviews of letters of intent and tax structuring to financial and tax due diligence, and share transfer agreement advisory.
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Valuation services
Our specialist team can help with all types of business valuations. The team has broad experience and continuously performs independent valuations, indicative value statements and fairness opinions (so-called second opinions).
On 20 June 2017, the Ministry for Finance presented a proposal regarding new legislation within the corporate sector.
The background of this proposal is the Government Commission on Corporate Tax's investigation that aimed towards equalizing the taxation on borrowed capital vs. equity. The Government has previously had problems in presenting actual legislation proposals and many people and organizations believed that the Commission's investigation would not end up in a government proposal. However, evidently the Ministry for Finance has published this extensive proposal with the purpose of "strengthening the competition and to create a dynamic corporate culture"
Swedish legislation comprises rules permitting full deduction for interest costs on borrowed capital. Only when the receiver is taxed low or exempted from tax on the interest income from related parties, there are limitations on the deductibility of interest. These limitation rules are complicated and have even been criticized by the EU to not be in line with EU-legislation.
The Swedish Ministry for Finance proposes the following (which now will be submitted to interested parties for comments):
- Current interest deduction restriction rules are made narrower only to be applicable on what the Ministry of Finance calls tax planning.
- A general limitation of interest deduction through only permitting 35% of EBIT,
- As a second option a limitation of interest through only permitting 25% of EBITDA
- The corporate income tax rate is lowered from 22% to 20%
- Deduction limitations on interest connected to certain cross-border hybrid situations
- New rules in relation to financial leasing agreements
- Depreciations on new buildings (office and apartment buildings) through an easement rule
- Tax losses carried forward can for a period of 2 or three years (depending on which rules is enacted) only be utilized up to 50% of the taxable income, i.e. 50% of the taxable income is always taxed regardless of the amount of tax losses
What will be the consequences?
The proposals are complex and it is rather difficult to foresee the effects at this stage. It is clear however, that for a debt free company, the proposed rules will mean a pure tax cut. On the other hand, the rules will for a highly leveraged companies, result in a tax increase that will increase in correspondence to the company taking up more debt.
To smoothen out the effects of the proposal and not to decrease the willingness to build more residential buildings, a special rule (see above) is proposed.
In a polemical article (Dagens Industri, 19 June 2017), The Minister for Finance Magdalena Andersson says that she is looking forward to receiving the proposal back from the parties to whom it has been submitted for comments and that the government subsequently will revert with a final proposal.
The criticism from the real estate sector was massive when the Government Commission on Taxation of Property (SOU 2017:27) presented its proposal for new legislation on real property taxation. In many parts of Sweden new construction of office and residential buildings is much needed. It is of interest to see how the real estate sector will perceive the proposal and, if it will be of the opinion that the proposed easement rule will be sufficient to stimulate new construction.
Since the government does not have majority in parliament it is difficult to determine how far the proposal will proceed in the legislative process.
Grant Thornton experts will now go through the proposal more thoroughly and subsequently present a deeper analysis.
The changes are proposed to enter into force as at 1 July 2018.