Sweden Tax Court Issues Advance Notice Clarifying Significant Connection Rules for Emigrating Taxpayers

The Swedish Tax Court March 9 issued Advance Notice No. 116-25/D, clarifying significant connection rules for emigrating taxpayers. The taxpayer, a Swedish citizen, permanently relocated to another country in 2017, while remaining a limited taxpayer in Sweden and limiting her stays there to approximately 82 overnight stays per year since 2017. The taxpayer sought clarification on whether the purchase of her adult son’s tenant-owned apartment in Stockholm would result in her having a significant connection to Sweden, even though her purpose in acquiring the apartment would be to use it when she is in Stockholm and visiting her remaining family, ...