Sweden has proposed a statutory definition of “permanent residence” in the Income Tax Act, introducing day-count thresholds of 160 days per year or 120 days over two consecutive years to determine unlimited tax liability. The changes are scheduled to take effect from 1 January 2027.
The Swedish government has proposed introducing a statutory definition of “permanent residence” in the Income Tax Act, a key concept used to determine whether an individual is subject to unlimited tax liability in Sweden.
An individual who is considered to be permanently staying in Sweden is generally regarded as having unlimited tax liability there. This means that the individual is liable to tax in Sweden on all income earned both in Sweden and abroad.
At present, the term permanent stay is not defined in the Income Tax Act (1999:1229), and determining whether a permanent stay exists can often be complex. The legislative proposal therefore suggests introducing a definition of the term in the Income Tax Act.
Under the proposal, permanent stay would be defined as a stay that, during a calendar year, comprises more than 160 days of presence, or more than 120 days of presence if the number of such days also exceeded 120 during the immediately preceding year. Only days that include an overnight stay will be counted as days of presence. The proposed definition would apply to all provisions of the Income Tax Act in which the term permanent stay appears.
The bill also sets out when a period of permanent residence begins and ends and includes transitional rules allowing days spent in Sweden during 2026 to be considered when assessing the 120-day threshold for 2027.
The proposed legislative amendments are intended to enter into force on 1 January 2027.
This announcement was made on 28 May 2026.
