The France-Sweden tax treaty protocol will enter into force on 29 August 2026, introducing BEPS-aligned changes to the Mutual Agreement Procedure and treaty benefit rules, with the amendments applying from 1 January 2027.
The amending protocol to the 1990 income and capital tax treaty between France and Sweden will enter into force on 29 August 2026.
It updates the treaty’s preamble and provisions on the Mutual Agreement Procedure and treaty benefits.
The protocol replaces the preamble in line with OECD/G20 Base Erosion and Profit Shifting (BEPS) minimum standards and amends Article 25 (Mutual Agreement Procedure). Taxpayers may present qualifying cases to the competent authority of either Contracting State.
The protocol also adds Article 28A (Entitlement to benefits), under which a treaty benefit may be denied where obtaining that benefit was one of the principal purposes of an arrangement or transaction, unless granting the benefit is consistent with the object and purpose of the relevant treaty provisions.
The changes are intended to address treaty abuse and broaden access to the Mutual Agreement Procedure. The protocol applies from 1 January 2027.
Earlier, France published Law No. 2026-510 of 15 June 2026 in the Official Gazette, providing for the ratification of the protocol to the 1990 income and capital tax treaty with Sweden.
