The protocol, aligning the treaty with OECD BEPS standards, revises key articles and adds a new provision on entitlement to benefits.
The French Senate gave its approval to the legislation ratifying the outstanding protocol to the 1990 income and capital tax agreement with Sweden on 29 October 2025.
Signed on 22 May 2023, this protocol updates the treaty in line with OECD BEPS standards, includes revisions to the preamble and Article 25 on the Mutual Agreement Procedure, and introduces a new Article 28A on Entitlement to Benefits.
It will enter into force 30 days after the exchange of ratification instruments and apply from 1 January of the following year.
Earlier, France’s Council of Ministers approved the amending protocol to the 1990 France–Sweden Income and Capital Tax Treaty on 11 July 2025.
