Ireland's lower house of Parliament has approved the second protocol amending the 1986 income tax treaty with Sweden, advancing ratification of an agreement that aligns the treaty with OECD BEPS standards, introduces a principal purpose test, and updates the Mutual Agreement Procedure with arbitration provisions.
Ireland’s Lower House of Parliament approved the second protocol amending the 1986 income tax treaty with Sweden on 15 July 2026.
Signed on 3 June 2026, the protocol introduces several updates to the treaty.
It replaces the preamble to align with OECD BEPS standards, removes the specific limitation on benefits provisions from Articles 11 (Dividends), 12 (Interest), and 13 (Capital Gains), and revises Article 27 (Mutual Agreement Procedure).
The revised Article 27 allows cases to be presented to the competent authority of either Contracting State and introduces arbitration provisions for cases that remain unresolved. The protocol also adds a new Article 28A (Entitlement to Benefits), which establishes a principal purpose test for determining eligibility for treaty benefits.
The protocol will enter into force 30 days after the exchange of instruments of ratification. Its provisions will apply from 1 January of the following year.
