Response to interpellation 2025/26:548 on effective taxation upon relocation

Finansministern Elisabeth Svantesson (M)

Mr. Speaker! I hope that everyone here at the podium has had some nice weeks – also everyone else in the room, of course.

Mathias Tegnér has asked me whether the issue of exit tax is being prepared at the Government Offices, whether I intend to take any initiatives to ensure that large unrealized capital gains cannot evade Swedish taxation through relocation, and whether I consider today's ten-year rule sufficient to counter tax planning through relocation or if I see a need to modernize the regulatory framework.

The question of a potential reform of the so-called ten-year rule is still being prepared in the Government Offices. As I have noted in several interpellation debates with Mathias Tegnér during recent years, the question of changes to the existing relocation taxation is complex, and there are different solutions to the problems that, among others, the Swedish Tax Agency and the National Audit Office have highlighted regarding specifically the ten-year rule. It is important that a potential new regulatory framework in Sweden does not entail negative effects on entrepreneurship and the business climate or complicates the recruitment of foreign expertise in an unjustified way. It is also important to have clear and distinct rules that do not create unnecessary complications for ordinary people and ordinary entrepreneurs.

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Mathias Tegnér (S)

Mr. Speaker! Thank you, Minister for Finance, for the answer!

I actually think the answer contains an important message. The Minister for Finance notes that there are problems with today's ten-year rule and explicitly refers to both Skatteverket and Riksrevisionen, who have noted this. That is good, because then we should at least be able to agree on the description of the problem.

The ten-year rule exists so that Sweden can tax certain capital gains even if the owner leaves the country. The government's expert agencies have, as we have heard, been very clear that the rule does not always function as intended. The Swedish Tax Agency has stated that the ten-year rule has major flaws and that it is not particularly effective.

One of the problems is that Sweden's right of taxation can be limited through our tax treaties. This means that large capital gains that have been built up over many years in Sweden are not taxed in our country when the owner moves abroad. I mean that it is a problem. Another person who considers it a problem is the Finance Minister's Moderate representative, Anders Borg. When it was revealed that there were problems with the ten-year rule in the 2000s, he, unlike Finance Minister Elisabeth Svantesson, chose to act.

So, this is not about taxing people because they move from Sweden. It is not about ordinary wage earners who take a job abroad. This is primarily about large unrealized capital gains. It is companies that have started in Sweden, grown in Sweden, and operated in Sweden, and where the shares are ultimately worth tens or hundreds of millions of kronor, and where the entire value increase has occurred while the owner has lived and operated in our country.

The question is then quite simple. Should it be possible to eliminate Sweden's opportunity to tax the value increase through relocation? I do not think so. I would actually like to say that it is completely unreasonable. On the other hand, it is the case that there is not just one solution. This does not mean that every model of an exit tax would be good. The Swedish Tax Agency came up with a proposal in 2017 that received extensive criticism and which was not implemented by the then Social Democratic government.

A regulatory framework must, of course, be compatible with EU law, safeguard business, safeguard mobility, and not create unreasonable consequences for people moving between countries. That is precisely why the previous government chose to appoint an inquiry to find a better and more accurate solution, but that inquiry was shut down by the current government and the Minister for Finance. That is where I believe the Minister for Finance is still responsible.

That unrealized values generated in Sweden should be taxed here is a matter of course for us Social Democrats. It is in line with international tax law and tax principles. Even Anders Borg saw this as a matter of course. Do Elisabeth Svantesson and the Moderates not think that these multi-millionaires should be taxed?

The government has almost had four years. The Finance Minister says that the issue is still being prepared. At the same time, the Finance Minister's party friends in the Committee on Taxation have expressed, here in the chamber of the Swedish Riksdag, that the government and the Moderaterna do not intend to act.

Then it becomes natural to ask the question: Which of these two statements is true? If the Finance Minister really means business with the fact that there are problems with the ten-year rule, the obvious question becomes: How long shall the matter be prepared?

Does the Finance Minister want to solve the problem, or is it just lip service?

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Eva Lindh (S)

Mr. Speaker! I thank Mathias Tegnér. I have followed my colleague's tireless work in the issues that he is truly engaged in, and this is one such issue. I have also followed the answers that the Minister for Finance has given.

Today, the Minister for Finance says from the rostrum that she also sees the problems. That is why it is so strange that nothing has actually been done. That it is being prepared in the Government Offices is a response we get quite often, but how can we know that is really the case? What is it that has been done?

Mathias Tegnér says here that this is a complex issue. One cannot just throw out a proposal, but one must investigate the consequences of a change. That is exactly why it is so strange that an investigation that was underway was laid down.

A government naturally has all the possibilities to change the investigation and give other directives. But to scrap the investigation cannot be interpreted as anything other than that one does not think this is important. Therefore, I actually also wonder if we can get an answer from the Minister for Finance here today – after Mathias Tegnér's tireless commitment and debates on this, throughout the entire mandate period. As it stands now, this is another example of the diminished credibility in the economic policy, which is shown by the Moderaterna and the entire government.

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Finansministern Elisabeth Svantesson (M)

Mr. Speaker! Thanks, again, to Mathias Tegnér for this discussion!

It is almost four years since we formed a Moderate-led government and I became Finance Minister. It can be said calmly that it was a rather large cleanup job that needed to be done in several areas, for example, the crime which was at a level where children murdered children, where many did not dare to go out during the day at all, and where the elderly were being defrauded. The list can be long. Sweden was unsafe. At the same time, there was war in our vicinity. The government, in broad agreement, has brought Sweden into a NATO membership and into a work of strengthening the defense. The third part, Mr. Speaker, concerns an inflation that was sky-high. Sweden had a low growth rate, and there was much to do to strengthen the households' economy in various ways.

That cleanup work, Mr. Speaker, we have now done many times over. Why is it important? Yes, it is important because we now see that the growth this year will be higher than in previous years. We see that the economy has turned and that we now have an economic recovery.

Mr. Speaker! September 13 is the election. I visualize a door where it says September 14. What will happen then? I will soon return to Mathias Tegnér's question, but for me, there are two very clear alternatives. One alternative is a Moderater-led government that continues the work of making Sweden richer after some really tough years, where Sweden's and the Swedes' economy shall be strengthened and where my goal is that Sweden shall have the highest prosperity within ten years.

It is about continuing to strengthen people's finances. It is also about, which touches upon the question from Mathias Tegnér, ensuring that companies grow, want to come here, and want to invest. In a very turbulent world, the pressure is enormous on countries that have a large export sector, for example Sweden.

I want to continue to work on all of this. Companies should stay here and invest here, and just as the interpellor mentions, taxes are extremely central, both so that companies specifically will want to be here and so that people will want to go to work, so that effort pays off and so that investments stay here.

There are a number of parts to work with, and the question from the interpellator is naturally one of them. But it is also all about order and about priorities. For me and the government, it is very important to also push back against the criminal economy. We will, of course, work to counteract both tax evasion and aggressive tax planning, and the government does this both in the EU and in the OECD. It is completely central that no one should flee our rules. No one should be able to avoid participating and taking responsibility and paying for what we need to do together. But I also have a focus on the economy growing and that more companies should be here and stay here. I can say that Donald Trump has cost Sweden's economy and the Swedes quite a lot of money. Every year, we expect approximately 160 billion lower GDP due to the American policy.

What do I want to say with all this? Yes, that the economy should grow. Taxes must absolutely be designed so that people both want to work and run businesses. All forms of cheating, whether it concerns smaller amounts from Försäkringskassan or large billion-dollar amounts that one actually aggressively tax-plans with, we will work on from start to finish.

I thank Mathias Tegnér for raising the issue; I will come back to it.

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Mathias Tegnér (S)

Mr. Speaker! Thank you, the Minister for Finance, for the answer, even though it is obvious that the Minister for Finance does not want to talk about what my interpellation is about, namely what and how unrealized capital gains accumulated in Sweden shall be taxed when the person in question moves out.

I want to confirm that I also think that questions about safety, war, Nato, inflation, household finances, growth, the economic cycle, Trump, and the Sweden Democrats are important. But that is not what this interpellation is about.

Questions about growth and justice are central in our country, and when we talk about entrepreneurship, I think a perspective is missing in the Finance Minister's answer. Is it reasonable that an ordinary wage earner, a kiosk owner in a square somewhere in our capital, or a painter who has started a company and perhaps hired a person should pay tax while a small group of successful entrepreneurs who can afford expensive tax lawyers should avoid it? That is actually what it is about – justice. Why should some entrepreneurs pay tax but not others?

I am the first to confirm that entrepreneurship is extremely important for Sweden. Issues such as free trade, good access to venture capital and good regulations are extremely important. I have personally written a book on industrial policy which I believe I handed over to the Minister for Finance at some point; I am not sure if the Minister for Finance has read it. Issues of trust, education and infrastructure are also completely central for us to have a good business system. But also issues regarding the tax system and fair taxes are important.

That is why I think it is relevant to ask the question about the ten-year rule. In the Finance Minister's opening response, she confirms that there are actually problems. The Swedish Tax Agency has said it and so has the National Audit Office. But after that, we end up in a situation where the Finance Minister states that the question is complex.

I want to confirm: The question is complex. That was why it was reasonable that an investigation was commissioned, an investigation that was to try to find smart solutions to the problem. But if one says that the question is complex at the same time as one lays down the investigation, the question becomes: What does the government intend to do? Now I have given the Minister for Finance four chances over four years to answer that question. But once again, the Minister for Finance is indebted to the answer.

The Minister for Finance says, as mentioned, that the issue is complex, which I want to confirm. But at some point, a preparation must also transition into politics. Therefore, I would like to take the opportunity to give the Minister for Finance another chance to answer my question: Did the government intend, at all, to present proposals that address the issue of the ten-year rule that is not working? Yes or no?

If the answer is still that the question is being prepared, the question is how long it will be prepared. Or is it as the Finance Minister's party friends have said, namely that the Moderates and the government do not intend to do anything about this question? Could the Finance Minister not simply admit that in that case?

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Eva Lindh (S)

Mr. Speaker! I would like to thank you for this debate, but there was no answer to Mathias Tegnér's question at all. There is, however, a chance to answer whether the government has taken this question seriously. Does one realize the complexity? Will you appoint an inquiry to actually do something about this?

The Minister for Finance spends a considerable amount of time talking about having cleaned up. We may have different opinions on the need to clean, but here the vacuum cleaner seems to have cleaned up a great deal that perhaps should not have been cleaned away, for example an investigation that could have provided a basis for carrying out precisely what the interpellor is requesting.

The Minister for Finance says that there are two alternatives after the election – an M-led government and an S-led government. When it comes to economic policy, I look forward to an S-led government that takes economic policy, growth, entrepreneurship, and everything else seriously.

I miss the seriousness that the Moderaterna have nevertheless shown previously when it comes to economic policy. Now, credibility is missing. They have borrowed for large tax cuts, which will affect future generations very much.

We need to get answers to the interpellant's questions. We have waited for an entire parliamentary term.

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Finansministern Elisabeth Svantesson (M)

Mr. Speaker! During this parliamentary term, there is probably no issue that I have discussed and debated as much in this chamber as the ten-year rule. It honors Mathias Tegnér that he continues to raise it.

My answer is the same as before in the sense that the government has done a lot regarding, for example, tax evasion. As I mentioned, we are working hard on this in both the EU and OECD, which the member also knows.

Mr. Speaker! During the chairmanship, we led the work on an update of the EU's list of non-cooperative jurisdictions, as it is called in tax language. We also led the negotiations on the proposal on VAT in the digital age, ViDA. It concerns and aims to stop, for example, VAT fraud. Furthermore, we have been proactive in the negotiations on reporting and exchange of information on crypto-assets, in order to reduce tax evasion and tax avoidance there. Tax avoidance is an important issue to work on.

Everyone who lives in Sweden shall participate and contribute. Everyone who earns money in different ways from their company or their work shall, of course, participate and bear the common burden. No one shall escape this. That is my firm opinion. That is why, Mr. Speaker, these four years have been so characterized by the subject of household finances but also the Swedish economy.

Mathias Tegnér said that the question of fair taxes is also important. I agree with that, and I do not think that taxation in Sweden has been completely fair over the years. Therefore, I see to it that more people get to keep more of their salary. Therefore, we see to it that the tax system shall reward effort. The taxes we collect in both state, municipality, and regions shall not be higher than what is required to do what needs to be done. One must also use the tax money in the very best way and dare to prioritize away sometimes. There will be another interpellation debate about that a little later.

Justice for me is that the person who sets the clock in the morning or in the evening – one works a bit differently – and goes to work or runs a business, small or large, should feel that we have a system where we do not collect higher taxes than we must and that we use the money in the best way. There is a dividing line between our two different sides.

Mr. Speaker! I want to say something briefly about the work on, for example, incorrect payments during these years. We must remember that during the recent years and the last decade, the criminal economy has grown significantly and also penetrated our welfare systems. The government has, for example, established a payment authority, which has already led to the discovery of incorrect payments of quite large sums. It will become even more so when that authority is fully operational.

We have carried out a whole range of measures regarding the census to get the best picture of who is in Sweden, both billionaires and those who live on different forms of benefits. We simply need to know who is here and that they are also fulfilling their obligations. We shall also not pay out money to those who live outside Sweden, if they are not entitled to it.

We have given the Swedish Tax Agency both more and sharper tools to stop VAT fraud, as I mentioned earlier.

The list can be long. We push back against cheating and perhaps above all the criminal activity, which is a contributing cause to the deadly violence and the crime we see.

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Mathias Tegnér (S)

Mr. Speaker! Thank you, Minister for Finance, for the answer! After this debate, I think one thing has become very clear. The government is aware of the problem. The Swedish Tax Agency and the National Audit Office have pointed out the deficiencies, and the Minister for Finance himself says that the issue is complex and is still being prepared. But the years go by and very little happens. Unfortunately, I recognize the pattern.

When it comes to tax evasion, the government is quick with the big words. They say the issue is important. They refer to the EU. They refer to the OECD. They refer to tax treaties. They refer to the preparation. But when it comes to the concrete Swedish measures, it becomes significantly thinner.

The investigation into more efficient taxation upon moving abroad was, as mentioned, discontinued. The annual follow-up of the tax error disappeared. When we ask what is being done about well-known loopholes in the tax legislation, we are repeatedly told that the issue is being prepared. It is not reasonable.

I cannot help but wonder whose interests the government and the Minister for Finance are serving. A tax system ultimately relies on legitimacy. Ordinary wage earners cannot choose whether they want to pay tax. Ordinary small business owners cannot buy their way out of taxation. We cannot accept a system where those who have large capital assets and the means for advanced tax consulting have the opportunity to exploit loopholes in the tax rules. These are loopholes that the government knows about but does not have the energy to close.

This is not about being against entrepreneurs – on the contrary. The vast majority of Swedish entrepreneurs do the right thing. They pay tax. They build companies. They create jobs. That is precisely why it is unreasonable that some can gain a competitive advantage through aggressive tax planning.

My conclusion after today's debate is simple. The problem is not that the government is unaware of tax evasion. The problem is that the government time and again chooses to do nothing about it. Sweden cannot afford four more years with an SD-led government.

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Finansministern Elisabeth Svantesson (M)

Mr. Speaker! I thank you for this discussion. I have been clear that the government is actively working to prevent tax evasion and large-scale fraud and schemes that do not belong here.

On September 14, Mr. Speaker, I hope that the work we have begun with building Sweden safer, wealthier and stronger shall continue. It does so by us continuing to facilitate for entrepreneurs and investments and for those who want to come to Sweden and grow. We also do it by ensuring that effort will always pay off. People who struggle shall feel that it is worth the effort. Our society is built on that everyone is included and takes responsibility and that cheating, fraud and everything in the vicinity of that is countered.

Mr. Speaker! The alternative on September 14 is four parties where I actually believe the party leaders haven't even drunk coffee together. They would prefer not to be seen in a picture together. They would prefer only to talk about their own politics in all parts. Here we have an environmental party that told last week that they want to raise fuel prices, have higher immigration, and abolish nuclear power and ensure that no new one is ever built. Here we have a Left Party leader whom I have met several times in debates and who is very honest and open about his politics, which I appreciate, and who tells about all the taxes that will burden both hard-working people and companies in Sweden. They are, so to speak, completely turning the picture around.

What makes Sweden rich and strong is not a system with higher taxes, shorter working hours, and abolished earnings deductions. We shall not work less; instead, in difficult times, we must all help each other.

Mr. Speaker! After the election, our alternative will hopefully prevail.

The interpellations debate was hereby concluded.

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