The Netherlands and Sweden signed a new income tax treaty, replacing the 1991 agreement to modernise provisions, strengthen legal certainty, prevent double taxation, and incorporate OECD Base Erosion and Profit Shifting (BEPS) minimum standards with mandatory binding arbitration for dispute resolution.
The Netherlands government has announced that it has signed a new income tax treaty with Sweden on 24 June 2026.
This new tax treaty replaces the 1991 agreement between the two countries to align with both countries’ current tax policy objectives. It also modernises existing provisions and introduces several significant changes to strengthen legal certainty and prevent double taxation.
The treaty incorporates measures to prevent treaty abuse and meets the minimum standards established by the OECD Base Erosion and Profit Shifting (BEPS) project, with several additional safeguards. A significant feature is mandatory and binding arbitration, allowing independent arbitrators to resolve disputes over treaty interpretation if the Netherlands and Sweden cannot reach an agreement. This mechanism provides taxpayers with additional legal certainty regarding double-taxation prevention.
Before entering into force, the treaty will be submitted to the Council of State for advice and subsequently presented to Parliament for approval.
The treaty will enter into force after the ratification instruments are exchanged.
