HM Revenue & Customs has published a memorandum of understanding with Sweden detailing the arbitration procedures under Article 23 of the UK-Sweden Double Taxation Convention, including the process for requesting arbitration through the mutual agreement procedure.
The UK’s HM Revenue & Customs (HMRC) has published a memorandum of understanding (MoU) with Sweden setting out the arbitration procedures under Article 23 of the 2015 UK-Sweden Double Taxation Convention, as amended by the 2021 Protocol.
The MoU was signed on 9 June 2026 and announced on 30 June 2026.
The memorandum provides detailed guidance on how taxpayers can request arbitration under the mutual agreement procedure (MAP). It outlines the requirements for submitting a written request and the information and supporting documents that must be provided.
The MoU also explains the process for establishing the arbitration panel’s terms of reference, including the issues to be resolved and the deadlines that apply during the proceedings.
HMRC said the guidance has been added to its UK-Sweden tax treaty documentation, providing detailed procedures for applying the arbitration provisions under Article 23 of the Convention.
