Subject-to-tax clauses in Swedish double tax conventions concluded between 2004 - 2014

Abstract: The thesis deals whit double tax conventions and double non-taxation. The thesis aim is to analyse the Swedish double tax conventions concluded between 2004 and 2014 in order to find out whether the double tax conventions contain a subject-to tax clause. In totally 11 conventions were analysed and subject-to-tax clauses were found in two conventions. The benchmark for the research is the model for Swedish double tax convention designed by the finance ministry. In this model there is a subject-to-tax clause in article related to capital, which presumably could mean that it was intention of the Swedish government to have this clause in there double tax conventions.