Access to Corresponding Adjustments and the Role of Courts, Tax Administrations and Competent Authorities – New Case Law on Article 9.2 of the Nordic Tax Treaty

Journal
Hagelin, J.
Sweden
International Transfer Pricing Journal 2025 (Volume 32), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

In this article, the author discusses a recent case from the Supreme Administrative Court in Sweden relating to corresponding adjustments in article 9.2 of the Nordic Tax Treaty. It specifically deals with the ability of administrative courts to apply article 9.2, namely, whether decisions by the Swedish Tax Agency not to make corresponding adjustments are appealable to the courts.