Response to interpellation 2024/25:719 on deficiencies in the regulatory framework surrounding capital insurance
Translated from Swedish by AI; the translation may contain errors. The Swedish text is the original.
Summary AI, written in advance
M considers it a priority to reduce risks of tax evasion 1 and that Sweden actively contributes to international cooperation 1. M argues that investigations take time and that the Swedish capital market must be protected 2 3. M considers that things should be done in the right way to ensure order and stability 4 and that changes in the taxation of redemption procedures reduce tax avoidance 4, but emphasizes that changes must be made with respect for pensioners' returns 4. S argues that the government is sitting on its hands despite the Swedish Tax Agency having pointed out a tax loophole 5 6 7 and demands that an investigation be appointed 6 7. S considers that tax loopholes risk leading to suboptimal capital allocation 7.
Written by AI in advance and may contain errors. The numbers lead to the speech a statement builds on; check against the text below.
Statsrådet Niklas Wykman (M)
Madam Speaker! Mathias Tegnér has asked the Minister for Finance what measures the Minister and the Government intend to take to close the window for advanced tax planning. The interpellation has been handed over to me.
It is central that there is a wide range of different products on the Swedish savings market. Capital insurance constitutes an alternative to, among other things, investment savings accounts. The form of savings shall not be able to be used for tax evasion.
It is a priority for the government to generally reduce the risks of tax evasion. Work is ongoing continuously, and there are several examples of important changes that the government has implemented.
Sweden contributes actively to the work taking place within the OECD and the EU, where, during the last decade, frameworks have been developed, among other things, regarding cooperation and automatic exchange of information between tax authorities. The latest examples are CARF and DAC 8, which have been designed to manage the risks associated with trading such assets through increased reporting and exchange of information on crypto-assets. Furthermore, the government has changed the taxation of certain redemption procedures in order to prevent foreign shareholders from avoiding the payment of Swedish coupon tax in connection with such procedures.
Mathias Tegnér (S)
Madam Speaker! To begin with, I would like to thank Minister for the Financial Markets Niklas Wykman for the answer.
The background to my interpellation is that the Swedish Tax Agency already during last year pointed out to the government that capital insurance is used for advanced tax planning. Fundamentally, it appears to be a matter of capital insurance having a lower degree of regulation than investment savings accounts, ISK. If I have understood the whole thing correctly, the limitations are too few regarding which assets can be placed in capital insurance and, above all, in which values. This means that there are opportunities for advanced tax planning within the framework of Swedish tax legislation today.
When the government's expert agency now attributes to the government – actually already last year – that there is a loophole in the tax legislation, I would at least believe that the government is shifting into high gear to close the loophole. According to the Swedish Tax Agency's assessment, it is, after all, about 1 billion kronor in tax loss every year. If I am not mistaken, such tax planning is also one of the Swedish Tax Agency's highest prioritized risks.
Madam Speaker! The background is clear. The Swedish Tax Agency has for several years, both this year and last year, pointed out that capital insurance is used for advanced tax planning. The latest audits have already resulted in hundreds of millions of kronor in increased tax payments. At the same time, the agency assesses that around 1 billion disappears every year. These are funds that could go to the welfare system – schools, healthcare, and elderly care – and to the defense. But right now, they are disappearing in tax evasion and tax fraud.
The Minister says that it is a priority for the government to generally reduce the risks of tax evasion. The Minister for Finance usually says the same in the interpellation debates I have had with her on this. But then I do not understand, Minister, why the government is sitting on its hands on the issue.
The Swedish Tax Agency already attributed it last year, but I am certain that nothing has been done. The Committee on Taxation invited the Minister for Finance during the spring. She sent her State Secretary, who stated that it was an important issue but that they were not working on it at that moment. I wrote an interpellation and received a response from the Minister for Finance and Markets which mainly concerned the work in the EU.
My question to Minister Wykman is therefore: Does the government consider this to be a problem? If the government considers this to be a problem, how does it intend to act?
Statsrådet Niklas Wykman (M)
Madam Speaker! Thank you, Mattias Tegnér, for an engaged contribution on an important issue!
It can perhaps be stated that the time spent has not exactly been advantageous because the Swedish Tax Agency submitted revised figures on this in May 2025 and had previously also recalled figures. If anything, it perhaps shows that it is not always the highest speed that leads to the best result.
Madam Speaker! There is probably no difference of opinion here. One can, of course, try to have a lively debate anyway, but as far as I can judge, our views correlate one hundred percent on the fact that we should counter tax-driven schemes or tax evasion in the systems. As recently as May, we also received revised data from the Swedish Tax Agency. The Swedish Tax Agency itself says that the issue needs to be investigated. Sometimes the Swedish Tax Agency feels it has the opportunity – it is occasionally undisputed – to itself interpret and assess rules or, for that matter, write out finished proposals. But here, the Swedish Tax Agency itself thinks that this needs to be investigated. And we know that with the Swedish investigation procedure, there is no rocket speed awaiting us ahead.
I believe we are in complete agreement on this. It is possible that I am misunderstanding what the member is looking for. The member also points out what is the concern: what is held in the capital insurance policies, valuation problems and so on, when it concerns unlisted assets or minority-owned companies.
The reason why the answer concerns the EU somewhat, Madam Speaker, is that there is a large difference in taxation here, if nothing else. In other countries, one can have capital insurance that is untaxed, and that is compared to paying tax in Sweden.
Depending on where one ends up regarding the unlisted assets in a company with few shareholders, the tax rate varies. But if one is within the dividend allowance, the tax is 20 percent. If one is not personally active in the company, the tax rate is generally 25 percent. If one is outside the dividend allowance, one must pay the tax on employment that one would normally have paid. If one is over 90 or 100 income base amounts, depending on whether it concerns dividend or capital gains taxation, it is 30 percent or the ordinary capital tax rate that applies. There are therefore a number of different tax rates here.
If one can instead place this in a foreign capital insurance without Skatteverket getting access to that information, one might remain untaxed. So it is still not the case as long as one remains within the information exchange. That is why it is so central to avoid the most aggressive setups. It is therefore central with the EU dimension, and it is central with the information exchange to access this.
Within the Swedish capital insurance and its taxation, one has an effective tax rate just under 20 percent, similar to that which applies for ISK. It is therefore not an untaxed asset, but it is an asset that can be compared with a taxation of perhaps 20 percent or some percentage point higher, 25 percent or even the full income tax. It can also be imagined that one can get the capital gains tax of 25 percent instead, if one has been inactive for a number of years. It can therefore happen that this affects the inactivity procedure rather than which tax one ultimately pays.
But, as I said, I cannot discern any difference of opinion here. We received this from Skatteverket in May.
Mathias Tegnér (S)
Madam Speaker! Thank you, Minister, for the answer! I note that Minister Wykman is talking about quite a few other things than what this interpellation is about.
I agree with the Minister in principle that the EU is an important issue when it comes to tax evasion and tax fraud – not to mention the matter itself. But there have been, and there have been during this mandate period, a number of issues where there has also been a need for action from the government. I perceive – and I have had several interpellation debates with the Minister for Finance on this – that the government in several of these issues has actually sat on its hands. It is about exit tax, and it is about this. But it is also about taxation on dividend payments, which the Minister also mentions in his interpellation response.
But if we stick to the question that this interpellation is about, that is, the problem we see regarding capital insurance, it is the case that the government was notified by the Swedish Tax Agency for the first time during the autumn – I believe it was in December 2024 – that we have a problem in this area. Then it is true that they adjusted their communication in May 2025. The first communication thus came in December 2024, and an adjusted communication came in May 2025.
This means, however, that the government and Minister Wykman have been aware of this problem since December 2024 and have known that an investigation needs to be commissioned, either within the framework of our investigative system or within the framework of the Ministry of Finance. I agree with the Minister that our investigative system does not always move at rocket speed. Fundamentally, it is probably better that it goes a bit slower and is correct than that it goes fast and is wrong.
The challenge here is that the problem has been known since the autumn of last year and nothing has been done. No investigation has been commissioned. The issue has not been addressed at the Ministry of Finance. This means that the clock is ticking. If nothing happens during the autumn, it will have been a year since the government first found out that 1 billion in tax revenues is disappearing every year. And we are just sitting on our hands.
The central problem here is that the legislation is unclear. There is no clear regulation for which assets may be included in capital insurance policies or at what values. It is therefore not even certain that it is as the Minister says, that the effective tax rate becomes 20 percent, because there appear to be problems with how different assets are valued, which means that the effective tax rate possibly could be lower.
The Swedish Tax Agency is crystal clear. They say that a review is needed, either within the Ministry of Finance or in the form of a government public inquiry. The Swedish Tax Agency pointed this out already last year. Nothing happened. We invited the Minister for Finance to the Committee on Taxation during the spring. Nothing happened. And now we stand here. The Minister does not provide any information that they are now in the process of appointing this inquiry. In that case, we will soon have lost a year.
When will the government start acting to close this gap in the tax legislation? Or is it the case that the government only talks about how important it is to pay tax but actually thinks that it is only ordinary people who should pay tax? Are we going back to the time when the nobility and the upper class were tax-exempt? Why should only ordinary Svensson pay tax but not Moderate voters with high incomes? That is the feeling one gets when the government sits on its hands despite knowing that there is a tax loophole in Swedish legislation. Why do you not take action on this issue? When will the government move from words to action, Minister Wykman?
Statsrådet Niklas Wykman (M)
Madam Speaker! I can thank the member again for an engaged contribution on an important issue, where there, however, seems to be no difference of opinion on the merits. The Swedish Tax Agency submitted its petition in May, and we are, of course, analyzing it. We seem to share the member's perception that it seems reasonable as the Swedish Tax Agency says, that this should be investigated. I have no information to give here today regarding the appointment of such an investigation.
Beyond rhetoric and such, the member knows that it always requires some work and some analysis. Since May, a summer has occurred, and the Riksdag has still been in recess. It is of course fun that we can be here and debate and discuss an important issue today. But I believe the listeners will have difficulty agreeing with the description of the skill. I also think the member may think it is good that Skatteverket took its time and was able to come in with an updated and probably more correct description of the problem in May.
These problems with capital insurance are well known. They have existed for a long time; there is nothing new in this.
Then one might want to reflect a little. I have noted that Sweden receives a great deal of international praise for our capital market generally speaking. In Sweden, households participate both through their pension savings and through their private savings. The parties in the labor market are in that way highly involved in that we convert our savings during our working lives into better pensions when we become pensioners. Households participate in the financial markets in Sweden – primarily through investment savings accounts, but some also have capital insurance and so on.
This in turn means that there is available capital for companies that want to invest more or that want to test new business projects. It means that we in Sweden have by far much more of that type of entrepreneurship but also of listing than most European countries. In the last few days, we have seen that Bloomberg writes about how the entire EU now sees the Swedish capital market as a great example and something that the entire EU should follow. The EU Commission points to Sweden and the Swedish model for investment savings accounts as an example and something that all EU countries should introduce. This obviously means that one should not just rush forward thoughtlessly in this area. These are, after all, complicated issues. It is complicated law. These are analyses that need to be made.
Just as the Swedish Tax Agency states, it is important to counter tax evasion and tax errors. But as that same expertise can also state, it is important that one does not accidentally destroy anything in what is often highlighted as not only the EU's best capital market but one of the world's, alongside a number of other countries, best capital markets, which provide Swedish employees with better wages and better conditions.
That the problem must be solved, and that the Swedish Tax Agency pointed out in May that an investigation into this was needed, are self-evident starting points for us. The Social Democrats, I note, are more reckless in this. They want to come in and sabotage this model. Magdalena Andersson has several times been out and spoken about how, in different ways, one needs to destroy or worsen ISK, which the rest of the world and the EU look at as a model. We will not do that. We will protect jobs and wages in Sweden.
We will, of course, act forcefully against tax evasion and tax avoidance. It is easy to share the view that this needs to be investigated.
Mathias Tegnér (S)
Madam Speaker! We agree on a few things. We agree that investments are important for our society. The previous Social Democratic government acted forcefully to allocate both private and public capital to investments. In that respect, we agree.
However, it is not the case that tax errors, tax evasion, and tax loopholes lead to a favorable allocation of capital. Instead, capital risks being allocated to things that are suboptimal if there are tax advantages. There is nothing positive in the existence of tax loopholes in our tax legislation if one believes that investments are important for our society. As a Stockholmer, I usually proudly speak about how our capital region is the capital market that has the most investable capital per capita in the world after Silicon Valley.
In principle, investments are positive. On the other hand, errors in our tax legislation are not positive. That is where Minister Wykman becomes answerable. The Swedish Tax Agency submitted a memorandum as early as December last year, and since then, the government has sat on its hands. Then they adjusted their memorandum in May, but the problem still exists.
Now I want to inform Minister Wykman that we are at the threshold of September. It has thus been almost nine months since the first indication that there is a clear gap in our tax legislation. By then, Minister Wykman and the government should do the only reasonable thing and what their expert agency is requesting. Appoint an inquiry to solve the problem! Do not just stand in the chamber of the Riksdag and talk about it!
Statsrådet Niklas Wykman (M)
Madam Speaker! Mathias Tegnér does not seem to think that the new information from Skatteverket that was submitted in May has any significance at all. If Mathias Tegnér thinks that one should act on old information instead of new information, that is obviously up to him, but it is a very poor way to run a country. It is irresponsible, populist, erratic, and harmful.
We do not stand for that. Things must be done in the right way with the right information, order and clarity, safety and stability. That is also what we do. Mathias Tegnér may be poorly prepared or prefers sharp debate contributions over facts. The change of the taxation of redemption procedures was precisely about measures to reduce tax errors and remove opportunities for tax evasion. That is something we have done. Intensive work has been ongoing for a long time with a more efficient exchange of information to reach those who plan to cheat their way out of their entire tax payment.
These are difficult matters that are poorly suited for the type of strained rhetoric that Mathias Tegnér expresses.
There is, as far as I know, no one in the political system who thinks that tax evasion and tax avoidance are good. On the other hand, there are a number of responsible parties, for example those in the government, who think that these types of changes must be made with respect so that one does not destroy something else that works well, for example Swedish pensioners' returns on their pension savings or the functioning of the Swedish capital market. In that case, you need experts. In that case, you need to analyze. In that case, you need to know the law. In that case, you need to understand and do it in a good way.
We must not go back to those tax havens. Mathias Tegnér will surely remember who it was that drilled big holes for the richest so that they could avoid paying tax.
Source: The Swedish Parliament. The speeches come from the open data of the Riksdag, translated into English by AI, which may contain errors.