N9 - Limitation of interest deduction

A company deducting a negative net interest income under the EBITDA rule should attach the appendix to its income tax return. The same applies to companies that:

  • deducts the remaining negative net interest income from previous years,
  • deducts a negative net interest income that has arisen in another group entity, or transfers a negative net interest income to another group entity (so-called group equalisation).

A company that makes a deduction for a negative net interest income under the simplification rule must attach the annex to its income tax return if one of the following conditions is met:

  • the company is part of a community of interest; or
  • the company's negative net interest income exceeds SEK 5 million.

Thus, only companies that apply the simplification rule, have a negative net interest income of less than SEK 5 million and are not part of a community of interest, are not required to attach the appendix to their income tax return.

Swedish partnerships and legal entities taxed as partners abroad that have been owned by natural persons only throughout the tax year are not required to submit the appendix.

What's an alignment of interest?

A company is in an alignment of interest with another company if one or several of these definitions are fulfilled:

  • A significant influence or under essentially joint management.
    • one of the companies has, directly or indirectly, through an ownership interest or otherwise a significant influence in the other company.

    • the companies are mainly under joint management.

  • A significant influence
    • a company in which the divested company, directly or indirectly, through an ownership interest or otherwise has a significant influence in.

  • Parent companies and subsidiaries or under mainly joint management.
    • the companies are parent companies and subsidiaries.

    • the companies are mainly under joint management.

Read more about this in the legal guidance from Skatteverket - What is an alignment of interest?

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