Switzerland and Sweden have agreed on procedures for resolving tax disputes through arbitration if unresolved after four years.
The Swiss Federal Tax Administration (FTA) announced on 22 May 2025 that it had signed a mutual agreement with Sweden to formalise the procedures for tax-related arbitration between the two countries.
The agreement establishes clear guidelines for resolving disputes under Article 2026 of their 1965 tax treaty.
Under the updated framework, if a taxpayer’s case remains unresolved after four years through the mutual agreement procedure, the individual may request arbitration. The agreement sets out the process for submitting such requests, outlines how arbitrators are selected and appointed, and defines how arbitration decisions will be issued and enforced.
It applies to all arbitration requests submitted after 22 May 2025.
