Ireland and Sweden signed a second protocol to amend their 1986 income tax treaty on 3 June 2026, introducing OECD BEPS-aligned provisions, revising the Mutual Agreement Procedure, adding arbitration and Entitlement to Benefits rules, and removing certain limitations on benefits provisions.
Ireland and Sweden signed an amending protocol on 3 June 2026 to revise the 1986 income tax treaty, which had previously been updated by the 1993 protocol.
The second protocol amending the treaty introduces several key updates. It replaces the preamble in line with OECD BEPS standards, removes specific limitation on benefits provisions from Articles 11 (Dividends), 12 (Interest), and 13 (Capital Gains), and revises Article 27 (Mutual Agreement Procedure) to allow cases to be presented to the competent authority of either Contracting State and to include arbitration provisions for unresolved cases. In addition, Article 28A (Entitlement to Benefits) is added, establishing a principal purpose test to determine eligibility for treaty benefits.
Under the terms of the protocol, it will enter into force 30 days after the ratification instruments have been exchanged. The protocol will apply from 1 January of the calendar year following its entry into force.
