Svenska dubbelbeskattningsavtal genom tiderna : En historisk överblick från 1928 till nutid

Sammanfattning: In this thesis, the background and historical development to the Swedish double taxation treaties is studied. The main topic of the study has been to examine double taxation agreements between Sweden and other countries, with a focus on trends and changes as well as formal changes in the structure of the agreements over time. This thesis has been written using a legal history method. The study has been limited to providing an overview of the history of Swedish double taxation treaties since 1928 to the present.  The background to Sweden entering into double taxation agreements with other countries is based on the desire to harmonies conflicting tax rules with other nations and thus avoid double taxation for its citizens.  Sweden has been active in expanding its network of double taxation agreements over time, although the frequency of signing has shifted during certain periods. The shifts in the number of signed treaties from 1928 to today can be explained by, among other things, the Second World War, the emergence of new independent countries and a change of focus in the work of negotiating new double taxation treaties. The treaties have played a key role in preventing double taxation, facilitating trade and investment and improving diplomatic relations between countries.  The work on Swedish double taxation agreements is characterised by a desire for standardisation and uniformity. Previous treaties lacked harmonisation and uniformity, but after the model treaty, the treaties are characterised by much greater consistency. Sweden has consistently endeavoured to follow the model agreement, which has clearly influenced the design of the agreements and thereby created a common structure.  By studying Swedish double taxation treaties over time, it can be concluded that Sweden has had a strong interest in cooperating internationally in tax law to avoid double taxation, which is reflected in the high frequency of treaties over time and that Sweden's treaties invariably follow the structure and disposition of the model treaty. Despite this, Sweden’s has decreased recently, particularly in favour of information exchange agreements. This is problematic given that it is in Sweden's interest to continue developing its network of double taxation agreements.