N9 - Limitation of interest deduction, This year's deductions tab

At the top of the page, select which rule to use.

You can choose between

  • The EBITDA rule
  • The simplification rule

The EBITDA rule

EBITDA stands for Earnings Before Interest, Taxes, Depreciation and Amortization. According to the so-called EBITDA rule, a negative net interest income can be deducted by 30 percent of a deduction basis (deduction margin) that corresponds to a company's tax EBITDA, i e a taxable profit before interest, tax, write-downs and depreciation (Inkomstskattelagen, chapter 24, §24).

The simplification rule

According to the simplification rule, instead of what is stated in the EBITDA rule, a negative net interest income may be deducted by up to 5 million SEK without examining whether the amount falls within the deduction space (Inkomstskattelagen, chapter 24, §24. The amount limit is not affected by whether a company has extended or shortened the financial year.

Calculation of deduction basis and deduction margin (EBITDA rule)

This section needs to be filled in if the EBITDA rule is applied instead of the simplification rule.

D.1

The result here is the result after all other tax adjustments according to Inkomstskattelagen, except for any deduction limitation for negative net interest income according to Inkomstskattelagen, chapter 24, §24 and deductions for remaining negative net interest income and deductions for tax allocation reserves. Consideration must thus be taken to group equalisation in §28.

D.2

The deficit which, if applicable, is to increase the result may at most consist of the deductible deficit according to Inkomstskattelagen, chapter 40, §2. Any amount and group contribution barriers must be considered. The result shall also not be increased by more than one negative amount in item 1.

D.3

The result shall be increased by annual depreciation deductions and similar deductions in accordance with Inkomstskattelagen, chapter 18, §3., chapter 19, §4, §7 and §26 and chapter 20, §4, §7 and §17.

D.4

Economic associations shall increase the profit with deductions for so-called contribution dividends made in accordance with Inkomstskattelagen, chapter 39, §23. Furthermore, investment companies shall increase the profit less such dividends received as dividends that the investment company has deducted in accordance with Inkomstskattelagen, chapter 39, §14.

D.5

The result shall be increased by negative net interest income taken from item B.6 or in cases where group equalisation has taken place item C.6.

D.6

The result shall be reduced by a positive net interest income taken from item B.5 or in cases where group equalisation has taken place item C.3.

D.7

The result shall be reduced by the gross amount of the reported surplus from trading companies and legal persons taxed as shareholders abroad. Offsetting against any deficit from another trading company should not be made.

D.9

Economic associations shall reduce the result with dividends received, but not with more than dividends paid that have been deducted for the same taxation year. Furthermore, investment companies must reduce the result by receiving dividends that the investment company would have taken up if it had been a company that can hold a business-related share in accordance with Inkomstskattelagen, chapter 39 §32, but not by more than the amount that has been deducted for dividends.

E. Deductions for the negative net interest income for the year and remaining negative net interest income

In this section, companies calculate their tax deduction for the negative net interest income for the year. Regardless of whether a company has a positive or negative net interest income, deductions for remaining negative net interest income from previous years are also calculated here.

E.1

The negative interest income for the year is taken from item B.6 or in cases where group equalisation has taken place item C.6.

E.2

Deductions can be made with a maximum of the negative net interest income in item 1 and the deduction margin in item D.11, or a limitation according to the simplification rule in Inkomstskattelagen, chapter 24, §24.

E.3

Deductions can be made with a total of remaining negative net interest income from previous years, but not more than the deduction margin in item D.11 minus deductions for the year's negative interest net in item 2.

The simplification rule for companies in an alignment of interest

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?

If at least one company within an alignment applies the simplification rule according to Inkomstskattelagen, chapter 24, §2, the requested deduction shall be stated in this section for all companies within the alignment of interest. The requested deduction refers to amounts from item E.2 and C.2 from each company's appendix N9

E.4

The amount is transferred to the field Other recorded costs (4.3c) on the page Non-deductible recorded costs in Profit and loss planning.

E.5

The amount is transferred to Other non-recorded costs (4.4 b) on the page Other tax adjustments in Profit and loss planning.

E.6

Companies that according to Inkomstskattelagen, chapter 40, §19a shall increase the deductions for group contribution-blocked deficits shall in certain cases also reduce the deduction for the year's negative net interest income according to Inkomstskattelagen, chapter 24, §25. Such a reduction shall be made if the company may not fully or partially deduct the group contribution-blocked deficit that remains from previous tax years, may only partially deduct a negative net interest income according to the EBITDA rule and receives group contributions that are not included in a surplus calculated according to Inkomstskattelagen, chapter 40, §18-19 (group contribution block).

The reduction in the deduction for the year's negative net interest income shall be calculated in accordance with Inkomstskattelagen, chapter 24, §25a-b,and Inkomstskattelagen, chapter 40, §19c-d.

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