Tax residence in Sweden for U.S. citizens and green card holders

Sweden does not count 183 days: you are subject to unlimited tax liability, on worldwide income, if you actually live in Sweden (bosatt) or stay there on a permanent basis — at least six months in a row, even across two calendar years; regular yearly stays of four to five months can also count. After you leave you remain liable as long as you keep an essential connection with Sweden. U.S. citizens remain taxable in the United States wherever they live; dual residence is settled by Art. 4 of the 1994 U.S.–Sweden Convention, as amended in 2005, which treats a U.S. citizen or green card holder as a U.S. resident only with a substantial presence, permanent home or habitual abode in the United States.

Check your status: United States and Sweden

Free, no sign-up, about 3 minutes. Conclusion under U.S. law, compared with the law of Sweden and the tax treaty.

When Sweden treats you as a tax resident

The first test is whether you are resident in Sweden (bosatt): whether Sweden is where you actually live, with your main home there. In practice such people are registered as resident (folkbokförda). The number of days does not decide this — if you moved to Sweden to live there, you are subject to unlimited tax liability from the day you moved.

The second test is a permanent stay (stadigvarande vistelse): under the preparatory works and case law, a stay in Sweden of at least six months in a row, even if it spans two calendar years. Short trips away (holidays, trips home) do not interrupt it. Sweden does not count 183 days in a calendar year.

A stay shorter than six months can also be permanent if it recurs: the courts weigh the length, extent and regularity of the yearly visits. Five months in a row every year is a permanent stay (HFD 2018 ref. 30 I); four months together with other visits is too (HFD 2019 not. 26); about three months together with roughly a month of other visits is not (HFD 2018 ref. 30 II, HFD 2019 not. 27).

The third test applies only to people who used to live in Sweden (bosatt) and left: they remain subject to unlimited tax liability as long as they have an essential connection with Sweden. For Swedish citizens and people who lived in Sweden for at least ten years in total, such a connection is presumed for five years after they leave.

The presumption of an essential connection for five years after leaving applies to Swedish citizens and to people who were resident or stayed permanently in Sweden for at least ten years in total.

Without Swedish citizenship the presumption applies only if you were resident or stayed permanently in Sweden for at least ten years in total. If you do not know, we assume the presumption may apply.

An essential connection is assessed on all the circumstances together. As a rule the greatest weight goes to a former permanent home kept after leaving; family in Sweden, your own business or a holding that gives a significant influence over a Swedish company, citizenship and how long you used to live there also count. A holiday home alone does not, as a rule, create a connection; a long stay abroad weakens it. The presumption applies: it is for you to show that there is no connection.

Whether you «live» in Sweden is decided on the facts (home, move, registration as resident), so the conclusion is probable, not certain.

Sweden is where you actually live (bosatt), so you are subject to unlimited tax liability in Sweden (3 kap. 3 § point 1 IL) and pay tax on your worldwide income (3 kap. 8 § IL) whatever the number of days. In the year you move, unlimited liability runs from the day you settled in Sweden or began a permanent stay; before that, and after you leave (unless an essential connection remains), liability is limited.
You stay in Sweden for at least six months in a row (short trips away do not interrupt the stay) — this is a permanent stay (stadigvarande vistelse), and you are subject to unlimited tax liability in Sweden (3 kap. 3 § point 2 IL), on worldwide income. In the year you move, unlimited liability runs from the day you settled in Sweden or began a permanent stay; before that, and after you leave (unless an essential connection remains), liability is limited.
Every year you regularly stay in Sweden for five months in a row or more. The Supreme Administrative Court of Sweden held such a stay to be permanent (HFD 2018 ref. 30 I), even where the person lives abroad most of the year — so you are probably subject to unlimited tax liability in Sweden (3 kap. 3 § point 2 IL).
Every year you regularly stay in Sweden for about four months in a row and also make other visits. The court held a stay of four months every summer together with other visits of up to three weeks to be permanent (HFD 2019 not. 26), but not three months together with other visits of three to five weeks (HFD 2018 ref. 30 II, HFD 2019 not. 27). The outcome depends on the total extent of your stays: Sweden may treat you as subject to unlimited tax liability.
You left Sweden less than five years ago and the presumption of an essential connection applies to you (Swedish citizenship or at least ten years of residence there). With the ties you have kept, you remain subject to unlimited tax liability in Sweden (3 kap. 3 § point 3, 7 § IL) — on worldwide income.
You left Sweden less than five years ago and the presumption of an essential connection applies to you (3 kap. 7 § IL): until you show that there is no connection, Sweden treats you as subject to unlimited tax liability (3 kap. 3 § point 3 IL).
You used to live in Sweden and have kept an essential connection with it (a home, family, a business or a significant influence over a Swedish company, etc.) — Sweden probably treats you as subject to unlimited tax liability (3 kap. 3 § point 3, 7 § IL). The assessment looks at all the circumstances together, and a long stay abroad weakens the connection.

When you are a nonresident

You do not live in Sweden, do not stay there permanently and have no essential connection as a former resident — you are subject to limited tax liability in Sweden, only on certain Swedish-source income: pay for work in Sweden, Swedish pensions, board fees — SINK 22.5% (20% from 2027); income from Swedish real property — 30%.
You left Sweden less than five years ago and the presumption of an essential connection applies to you (3 kap. 7 § IL). You believe you have kept no ties, but it is for you to prove it: until Skatteverket agrees, you may be treated as subject to unlimited tax liability. If you prove it — limited taxation, only on income from Sweden.
You used to live in Sweden, but the presumption of an essential connection does not apply to you (five years or more have passed, or you have neither Swedish citizenship nor ten years of residence there). Whether you have an essential connection is unclear; without one you are subject to limited tax liability in Sweden, but Skatteverket may assess your ties (home, family, business) differently.
You have not stayed in Sweden for six months in a row, but it is unclear whether Sweden is where you actually live (bosatt). If it is, you are subject to unlimited tax liability whatever the number of days; if not, you are taxed only on income from Sweden. Keep evidence of where your home is and where you are registered as resident.

Where the rules of Sweden clash with U.S. tax rules

Collision: six months in Sweden while the U.S. also treats you as resident or citizen. Sweden treats you as subject to unlimited tax liability because you stay there on a permanent basis — six months in a row, or regular long stays every year; the United States taxes you on worldwide income as a citizen, green-card holder or substantial-presence resident. Art. 4 of the 1994 Convention decides treaty residence: a U.S. citizen or green-card holder counts as a U.S. resident only with a substantial presence, a permanent home or an habitual abode in the United States (Art. 4(1)(b)); dual residence is then settled by Art. 4(2) (permanent home → centre of vital interests → habitual abode → citizenship → mutual agreement). Even if the treaty gives residence to Sweden, the United States keeps taxing its citizens (saving clause, Art. 1(4)); double tax is relieved under Art. 23.
Collision: you live in Sweden while the U.S. also treats you as resident or citizen. If Sweden is where you actually live (bosatt), you are subject to unlimited tax liability there from the day you settle, whatever the number of days. A home in Sweden will usually also be a «permanent home available to you» under the treaty: if your only permanent home is in Sweden, Art. 4(2)(a) points to Sweden; with homes in both countries, the centre of vital interests decides. A U.S. citizen remains taxable in the United States either way (Art. 1(4)).
Collision: an essential connection with Sweden after moving to the United States. A former Swedish resident remains subject to unlimited tax liability as long as he or she has an essential connection with Sweden; for Swedish citizens and people who lived there for at least ten years the connection is presumed for five years after leaving. If you have moved to the United States, both countries then tax your worldwide income. Art. 4(2) of the Convention decides: if your only permanent home is in the United States, you are a U.S. resident for the treaty, and Sweden may tax only what the Convention allows — including gains on any property for ten years after you ceased to be a Swedish resident (Art. 13(7)), with a deduction for U.S. tax (Art. 23(2)(a)).
Collision: U.S. citizens stay taxable in the United States even as Swedish residents. Sweden taxes you on worldwide income as a resident; the United States taxes its citizens wherever they live. The saving clause (Art. 1(4)) lets the U.S. tax you as if the treaty did not exist, but keeps Art. 19(2) (social security benefits) and Art. 23 (relief). Relief works in steps (Art. 23(3)): Sweden deducts U.S. tax on U.S.-source income only up to the tax the Convention would allow on a non-citizen (for example 15% on portfolio dividends, Art. 10(2)(b)); the United States credits the Swedish tax remaining after that deduction, treating the income as Swedish-source to the extent necessary. The same applies to former citizens and former long-term residents for ten years.

What else to know

Sweden counts six months in a row, not 183 days. Sweden has no 183-day calendar-year test: a stay of at least six months in a row is permanent even if it spans two calendar years, short trips away do not interrupt it, and regular yearly stays of four to five months can also be permanent. The U.S. substantial presence test counts calendar-year days with a weighted look-back over three years, so the two counts rarely match: 190 days in Sweden spread over the year need not be a permanent stay, while five months in a row every summer may be.
Treaty residence test for U.S. citizens and green-card holders. Under Art. 4(1)(b) of the Convention a U.S. citizen or green-card holder is a U.S. resident for treaty purposes only with a substantial presence, a permanent home or an habitual abode in the United States. If you live in Sweden without any of these, there is no dual residence under the treaty and you are a resident of Sweden only; if you have one of them, Art. 4(2) decides.
Year of moving: Sweden splits the year, the U.S. does not for citizens. Sweden taxes by calendar year, but unlimited liability runs from the day you settled in Sweden or began a permanent stay until you leave (or for as long as an essential connection remains); for the rest of the year only income from Sweden is taxed. A U.S. citizen is taxed on worldwide income for the whole year; an alien may be a dual-status taxpayer in the year of arrival or departure. Match the periods so that the same income is not taxed twice, and if needed use the mutual agreement procedure (Art. 25 of the Convention).
Working in Sweden while not Swedish-resident. Pay for work physically performed in Sweden is Swedish-source income; non-residents pay SINK of 22.5% in 2026 (20% from 2027) or, at their option, ordinary taxation. If you are a U.S. resident under the Convention, Sweden may not tax it if all conditions of Art. 15(2) are met: no more than 183 days in Sweden in any consecutive twelve-month period, an employer not resident in Sweden, and pay not borne by the employer's permanent establishment or fixed base in Sweden (§ 6 a of the SINK Act has the same exemption). Self-employed: Art. 14 — only income attributable to a fixed base in Sweden. The United States credits the Swedish tax (Art. 23(1)); you may instead exclude the pay under § 911 if you qualify.
Swedish resident working in the United States: the six-month rule. If you are subject to unlimited tax liability in Sweden and work as an employee in the United States for at least six months, Sweden does not tax that pay to the extent it was taxed in the United States (sexmånadersregeln); after at least a year in one country the pay is exempt even if it was not taxed there for reasons of that country's law or practice (ettårsregeln). Short visits to Sweden do not interrupt the period if they do not exceed six days for each month of work (72 days per year). The one-year rule does not apply to public service (except export of services); neither rule applies to work on ships and certain aircraft. For the self-employed only the Convention applies.
Pensions, Social Security and government service. Under the Convention private pensions and annuities are taxable only in the country of residence (Art. 19(1)). Social security benefits — U.S. Social Security and Swedish public pensions, including the allmän tilläggspension — paid to a resident of the other country or to a U.S. citizen are taxable only in the paying country (Art. 19(2)); this rule survives the saving clause. Government salaries and pensions are generally taxable only in the paying country (Art. 20). Under Swedish domestic law a Swedish pension paid to a non-resident is subject to SINK of 22.5% (20% from 2027), with a tax-free SEK 3,799 a month on State pensions, as far as the Convention allows Sweden to tax it.
Expertskatt: 25% of pay tax-free for foreign experts. Foreigners who have not lived in Sweden in the five previous calendar years and come as experts, researchers or key staff to a Swedish employer pay, by decision of Forskarskattenämnden, no tax on 25% of their pay for up to seven years; the application is due within three months of starting work. From 1 Jan 2027, 30%, admission of Swedish citizens and a six-month application deadline have been proposed — check whether the law has been passed. For a U.S. citizen the relief lowers only Swedish tax: the U.S. still taxes worldwide income, and lower Swedish tax means a smaller U.S. foreign tax credit.
Leaving Sweden: essential connection, the ten-year rule and Art. 13(7). IL has no general exit tax for individuals, but: (1) former residents remain subject to unlimited tax liability as long as they have an essential connection (presumed for five years for Swedish citizens and people with ten years of residence); (2) gains on shares remain taxable in Sweden for ten calendar years after leaving (3 kap. 19 § IL); (3) the U.S.–Sweden Convention lets Sweden tax gains on any property for ten years after a former Swedish resident becomes a U.S. resident (Art. 13(7)), and Sweden then deducts the U.S. tax on those gains (Art. 23(2)(a)).
Social security: U.S.–Sweden totalization agreement. The United States and Sweden have a social security (totalization) agreement in force since 1 January 1987. It stops you paying social security contributions to both countries for the same work: an employee sent abroad by an employer for five years or less generally stays in the home system, and a certificate of coverage proves the exemption from the other system.
Which treaty applies: the 1994 Convention as amended in 2005. Between the United States and Sweden the income tax Convention signed in Stockholm on 1 September 1994 applies, as amended by the Protocol signed in Washington on 30 September 2005. It entered into force on 26 October 1995 (in Sweden it applies from 1 January 1996); the Protocol has been in force since 31 August 2006. The United States is not a party to the MLI, so the MLI does not modify it. Residence — Art. 4 (with Art. 4(1)(b) for U.S. citizens and green-card holders); saving clause — Art. 1(4)–(5); pay — Art. 15(2) (183 days in any consecutive twelve months); gains of former Swedish residents — Art. 13(7); pensions and social security — Art. 19; government service — Art. 20; relief — Art. 23; mutual agreement — Art. 25.

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Government of Sweden and the Government of the United States of America for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, signed at Stockholm on 1 September 1994, as amended by the Protocol signed at Washington on 30 September 2005 (Sweden: Lag (1994:1617), as amended by Lag (2005:1088)). The tests are applied in order — permanent home, center of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities. U.S. citizens remain taxable in the United States under the saving clause.

The treaty in detail: income, rates, the 183-day rule →

Terms you will come across in Sweden

bosatt: actually living in Sweden: makes you subject to unlimited tax liability whatever the number of days (3 kap. 3 § IL)
stadigvarande vistelse: permanent stay: at least six months in a row; short trips away do not interrupt it
väsentlig anknytning: a former resident's essential connection with Sweden; presumed for five years after leaving for Swedish citizens and people with ten years of residence
SINK: special income tax for non-residents: 22.5% in 2026, 20% from 2027
Skatteverket: the Swedish Tax Agency
expertskatt: relief for foreign experts: 25% of pay tax-free for up to seven years

Questions

Do I become a Swedish tax resident after 183 days?

Sweden counts a permanent stay of at least six months in a row rather than 183 days, even if the stay spans two calendar years; short trips away do not interrupt it. Regular yearly stays of five months in a row have been held permanent by the Supreme Administrative Court (HFD 2018 ref. 30 I). If Sweden is where you actually live (bosatt), the number of days does not matter.

I am a U.S. citizen — do I still pay U.S. tax if I live in Sweden?

Yes. The saving clause (Art. 1(4) of the Convention) keeps the U.S. right to tax its citizens even if the treaty makes you a Swedish resident. Sweden deducts U.S. tax on U.S.-source income only up to what the Convention would allow on a non-citizen, and the United States credits the remaining Swedish tax (Art. 23(3)). Social security benefits are taxed only in the paying country (Art. 19(2)).

Can Sweden still tax me after I move back to the United States?

Yes, in two ways. As long as you keep an essential connection with Sweden — such as your former home or a significant holding in a Swedish company — Sweden treats you as subject to unlimited tax liability, and the treaty tie-breaker then decides. And under Art. 13(7) of the Convention Sweden may tax gains on any property for ten years after you ceased to be a Swedish resident, deducting the U.S. tax on them.

Sources

Legislation and official guidance

3 kap. 3 § Inkomstskattelag (1999:1229) (IL) — Individuals are subject to unlimited tax liability (on worldwide income) if they: 1) are resident in Sweden (bosatt); 2) stay in Sweden on a permanent basis (stadigvarande vistas); 3) have an essential connection with Sweden (väsentlig anknytning) and previously lived there. The rule does not apply to staff of foreign diplomatic and consular missions, who are subject to limited tax liability under 3 kap. 17 § points 2–4.
Skatteverket — «Skattskyldighet» (limited and unlimited tax liability; updated 30 Jan 2026) — You are bosatt in Sweden if your actual home is in Sweden (and you are then required to be registered as resident — folkbokförd). A permanent stay is a stay in Sweden of at least six months in a row; short breaks, such as trips home, do not interrupt it. After you leave, an essential connection can arise from a home you keep, family, significant assets and the like. Anyone not subject to unlimited tax liability is subject to limited tax liability — only on certain income from Sweden.
3 kap. 7 § IL (essential connection) — A former resident's essential connection is assessed on all the circumstances together: Swedish citizenship; how long the person lived in Sweden; having no permanent residence at a particular place abroad; a stay abroad for study or health reasons; a home in Sweden equipped for year-round living; family in Sweden; business activity in Sweden; economic ties through assets that give, directly or indirectly, a significant influence over a business in Sweden; real property in Sweden; similar circumstances. A Swedish citizen, or a person who has been resident or stayed permanently in Sweden for at least ten years in total, is deemed to have an essential connection for five years after leaving, unless he or she shows otherwise.
3 kap. 8 § IL — People subject to unlimited tax liability pay tax on all their income — from Sweden and from abroad — subject to the exemptions in 3 kap. 9–16 §§ and to tax treaties.
3 kap. 17–18 §§ IL (limited tax liability) — Anyone not subject to unlimited tax liability is subject to limited tax liability — only on certain income from Sweden: pay, pensions and fees within the SINK Act (under IL, if you have opted for ordinary taxation); income from a permanent establishment or real property in Sweden; gains on Swedish real property and Swedish tenant-owner rights; dividends from Swedish economic associations, etc. Royalties from a business with a permanent establishment in Sweden count as income of that establishment. Interest is not on the list.
§§ 5, 6 a, 7 Lag (1991:586) om särskild inkomstskatt för utomlands bosatta (SINK), as amended by SFS 2025:1355 and 2025:1356 — Non-residents pay SINK on Swedish pay for work done in Sweden, pay from the Swedish State, a municipality or a region (wherever the work is done), board fees from Swedish companies, Swedish pensions and certain social benefits. The rate is 22.5% for income received after 31 Dec 2025 and 20% for income received after 31 Dec 2026 (seafarers' income — 15%). Pay from a foreign employer is exempt if you are in Sweden for no more than 183 days in any 12-month period, the employer is not resident in Sweden and the cost is not borne by its permanent establishment in Sweden (6 a §). The 6 a § exemption does not apply to hired-out labour working under the control and direction of a user in Sweden (a business taxable in Sweden, the Swedish state, a municipality or a region) (6 a § second paragraph), except for work in Sweden of at most 15 consecutive days and at most 45 days in a calendar year (6 b §).
Skatteverket — «SINK – särskild inkomstskatt för utomlands bosatta» (updated 30 Sep 2026) — SINK — 22.5% in 2026, 20% from 1 Jan 2027; no tax return is needed. Instead of SINK you can opt each year for ordinary taxation under IL: average municipal tax and State tax, deduction of expenses, mandatory return; the basic allowance applies if at least 90% of your earned income is taxed in Sweden. For State pensions there is a tax-free amount of SEK 3,799 a month (2026).
Art. 4(1)–(2) U.S.–Sweden Convention (Stockholm, 1 Sep 1994, as amended by the 2005 Protocol) — Resident = a person liable to tax in a State by reason of domicile, residence, place of management, place of incorporation or a similar criterion, but not a person liable there only on income from sources there. A U.S. citizen or green-card holder is a U.S. resident only if he or she has a substantial presence, permanent home or habitual abode in the United States; if also a resident of Sweden, his or her status is determined under Art. 4(2) (Art. 4(1)(b)). Dual-resident individual: (a) permanent home; if a home in both States, the State of closer personal and economic relations (centre of vital interests); (b) if that cannot be determined, or there is no permanent home in either State — habitual abode; (c) citizenship; (d) mutual agreement.
Art. 1(4)–(5) U.S.–Sweden Convention (saving clause) — The United States may tax its residents (as determined under Art. 4) and, by reason of citizenship, its citizens as if the Convention had not come into effect; a former citizen or long-term resident may be taxed under U.S. law for ten years after losing that status. Exceptions (para. 5): Art. 9(2), Art. 19(2), Arts. 23 (relief), 24 (non-discrimination) and 25 (mutual agreement); and Arts. 20, 21 and 28 for individuals who are neither U.S. citizens nor have U.S. immigrant status.
Art. 23 U.S.–Sweden Convention (relief from double taxation) — (1) The United States credits Swedish income tax to its citizens and residents. (2)(a) Sweden deducts from Swedish tax the U.S. income tax on income that the United States may tax under the Convention (except where taxed only by reason of Art. 1(4)), under Swedish law; the same applies to gains Sweden taxes under Art. 13(7). (3) For a U.S. citizen, former citizen or former long-term resident resident in Sweden: Sweden deducts U.S. tax on U.S.-source income only up to the tax the Convention would allow on a non-citizen; the United States credits the Swedish tax remaining after that deduction, and income is deemed to arise in Sweden to the extent necessary to avoid double taxation.
Art. 13(6)–(7) U.S.–Sweden Convention (gains) — Gains on property other than real property, permanent-establishment or fixed-base property, ships and aircraft, containers and royalty-type gains are taxable only in the State of residence of the seller (para. 6); but where an individual who had been a resident of Sweden has become a resident of the United States, Sweden may tax gains from the disposition of any property derived at any time during the ten years after he or she ceased to be a Swedish resident (para. 7).
§ 7701(b)(3)(A); Treas. Reg. § 301.7701(b)-1(c) — Substantial presence test: at least 31 days in the current year and at least 183 days counting all current-year days, 1/3 of the days in the first preceding year and 1/6 of the days in the second preceding year. Fractions are not rounded.
Treas. Reg. § 1.1-1(b) — U.S. citizens, wherever resident, are liable to income tax on income from all sources.
Art. 15 U.S.–Sweden Convention (dependent personal services) — Pay for employment exercised in the other State may be taxed there; but it is taxable only in the State of residence if the employee is present in the other State for periods not exceeding 183 days in the aggregate in any consecutive twelve-month period, the pay is paid by or on behalf of an employer that is not a resident of the other State, and it is not borne by a permanent establishment or fixed base of the employer there.
Art. 14 U.S.–Sweden Convention (independent personal services) — Income from independent personal services is taxable only in the State of residence, unless the services are performed in the other State and the income is attributable to a fixed base regularly available to the individual there.
26 U.S.C. § 911(a), (d)(1), (d)(6) — A qualified individual (tax home abroad and bona fide residence for an entire taxable year, or 330 full days abroad in 12 consecutive months) may elect to exclude foreign earned income and a housing amount; no foreign tax credit is allowed for taxes allocable to the excluded income.
3 kap. 9–13 §§ IL (six-month rule and one-year rule) — A Swedish resident who stays abroad for at least six months because of employment pays no Swedish tax on that pay to the extent it was taxed in the country of work (unless contrary to that country's law or a treaty); after a stay of at least one year in one country — even if it was not taxed there because of law, administrative practice or an agreement that is not a tax treaty. The one-year rule does not apply to work for the State, regions, municipalities and parishes of the Church of Sweden (except export of services) or to Members of the European Parliament; neither rule applies to work on Swedish, Danish and Norwegian aircraft or on ships (with a separate exception for foreign ocean-going ships). Short visits to Sweden (holiday, business trips) do not interrupt the period if they do not exceed six days for each full month of work or 72 days per year of work.
Arts. 19–20 U.S.–Sweden Convention (pensions, social security, government service) — Private pensions for past employment and annuities: taxable only in the State of residence (Art. 19(1)). Pensions (including the Swedish allmän tilläggspension) and other benefits under the social security legislation of a State paid to a resident of the other State or to a U.S. citizen: taxable only in the paying State (Art. 19(2)). Government pay: only in the paying State, unless the services are rendered in the other State by its resident who is its citizen or did not become resident solely to render them; government pensions: only in the paying State, unless the individual is a resident and citizen of the other State (Art. 20(1)–(2)).
11 kap. 22–23 §§ IL (expertskatt); bill referred to the Council on Legislation «Skatteincitament för forskning och utveckling» (June 2026) — Foreign experts, researchers and other key staff — non-Swedish citizens who have not been resident or stayed permanently in Sweden in the five preceding calendar years and intend to stay no more than seven years — pay, by decision of Forskarskattenämnden, no tax on 25% of their pay for up to seven years; the employer must be Swedish or have a permanent establishment in Sweden; the application is due within three months of starting work. Proposed from 1 Jan 2027 (for work starting after 31 Dec 2026): 30%, admission of Swedish citizens, 84 months that can be split, seven years without residence in Sweden, application deadline six months. Enactment not verified as of 10 Nov 2026.
3 kap. 19 § IL (ten-year rule) — A person with limited tax liability pays tax on gains from the sale of shares (delägarrätter), interests in Swedish partnerships and the like if in the year of the sale or in any of the ten preceding calendar years he or she lived or stayed permanently in Sweden. Shares in foreign companies are covered only if acquired during a period of unlimited tax liability.
SSA POMS GN 01701.005 — International Social Security (Totalization) Agreements — U.S.–Sweden agreement effective 1 January 1987.
SSA — U.S. International Social Security Agreements (list of agreements and entry-into-force dates) — SSA lists 31 agreements with their entry-into-force dates, from Italy (1 November 1978) to Romania (1 September 2026). Agreements eliminate dual social security coverage; employees sent abroad by their employer for five years or fewer generally stay covered by their home country; a certificate of coverage proves the exemption. Ukraine is not on the list.
U.S.–Sweden Convention of 1 Sep 1994 and Protocol of 30 Sep 2005 (Lag (1994:1617), as amended by Lag (2005:1088)) — Convention signed at Stockholm on 1 Sep 1994, in force 26 Oct 1995 (Förordning (1995:1232)), effective in Sweden from 1 Jan 1996; Protocol signed at Washington on 30 Sep 2005, in force 31 Aug 2006 (replaced Art. 4(1), adding 4(1)(b)). The English text is the only signature language. The United States is not a party to the MLI.
Skatteverket — «Belopp och procent – inkomstår 2026» — 2026: State income tax — 20% on taxable earned income above SEK 643,000; average municipal tax rate — 32.38%; tax on capital income — 30%; SINK — 22.5%; price base amount (prisbasbelopp) — SEK 59,200.
45 kap. 33 §, 46 kap. 18 § IL — 22/30 of a gain on the sale of a home (a private dwelling house or a tenant-owner right) in Sweden is taxable, i.e. effectively 22% at the 30% capital income tax rate.
Art. 4(1)(b) of the Sweden–United States Convention (as replaced by Art. III of the 2005 Protocol) — A United States citizen or an alien lawfully admitted for permanent residence (green-card holder) is a resident of the United States only if he has a substantial presence, permanent home or habitual abode in the United States; if he is also a resident of Sweden, his status is determined under Art. 4(2).
Art. 1(4)-(5) of the Sweden–United States Convention (as amended by the 2005 Protocol) — The United States may tax its residents and citizens as if the Convention had not come into effect; former citizens and long-term residents may be taxed under U.S. law for ten years after losing that status. Paragraph 5 keeps certain benefits, including Arts. 19(2), 23, 24 and 25.
Art. 4(2)(a) of the Sweden–United States Convention (1994/2005) — A dual-resident individual is deemed to be a resident of the State in which he has a permanent home available to him; if he has a permanent home available to him in both States, of the State with which his personal and economic relations are closer (centre of vital interests).
Art. 4(2)(b) of the Sweden–United States Convention (1994/2005) — If the State in which he has his centre of vital interests cannot be determined, or if he has no permanent home available to him in either, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c), (d) of the Sweden–United States Convention (1994/2005) — If he has an habitual abode in both States or in neither, he is deemed to be a resident of the State of which he is a citizen (c); if he is a citizen of both States or of neither, the competent authorities settle the question by mutual agreement (d; procedure in Art. 25).

Case law

Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 6034-17 (HFD 2018 ref. 30 I), 2018-05-30 — A person who, after moving to Portugal, planned to spend five consecutive months (May to September) in Sweden every year, plus Christmas and two short trips (182 days in Sweden and 183 in Portugal in total), stays in Sweden on a permanent basis and is subject to unlimited tax liability: a regular five-month stay is enough even if you spend most of the year abroad.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 6736-17 (HFD 2018 ref. 30 II), 2018-05-30 — A married couple who, after moving to Portugal, planned to spend June to August (about three months) in Sweden every year and to make irregular visits of about 30 more days in total do not stay in Sweden on a permanent basis. Stays shorter than six months are judged by their length, extent and regularity; six months in a row or more is, as a rule, a permanent stay.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 236-19 (HFD 2019 not. 26), 2019-10-30 — A woman living in Portugal who planned to spend about four summer months (mid-May to mid-September) in Sweden every year and to make irregular visits of up to three more weeks in total stays in Sweden on a permanent basis: four months alone would not be enough, but together with the other visits the stay is extensive enough to be permanent.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 2659-19 (HFD 2019 not. 27), 2019-10-30 — A woman living in Portugal who planned to spend three summer months, three weeks at Easter and up to two more weeks of irregular visits in Sweden every year does not stay in Sweden on a permanent basis: the total extent of the stays is not enough.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 6452-23 (HFD 2024 not. 19), 2024-03-25 — A Swedish citizen who left in 2017 (his wife in 2020) and kept the couple's tenant-owned flat — the former permanent home, which the couple now uses for holidays — and shares in other real property had an essential connection with Sweden in 2023 and 2024. A former permanent home kept after leaving usually weighs most.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 5346-19, 2020-06-08 — A married couple of Swedish citizens who sold their permanent home and, shortly before moving to Portugal, bought a flat they had never lived in and planned to use for holidays had no essential connection with Sweden: a holiday home alone does not, as a rule, create such a connection.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 3479-18 (HFD 2019 ref. 12), 2019-03-20 — A married couple of Swedish citizens who left in 2004 and lived in Switzerland had no essential connection with Sweden after moving to the Bahamas: the husband's significant influence over a Swedish business (a controlling stake in a Swiss group, acquired after 2010) was outweighed by the length of the stay abroad; holiday homes and forest in Sweden carry little weight.
Högsta förvaltningsdomstolen (HFD, Supreme Administrative Court of Sweden), 1562-20 (HFD 2020 not. 44), 2020-10-22 — A Swedish citizen who, through a holding company, indirectly held 18.3% of a Swedish operating company he had founded while living in Sweden, and kept a holiday home, had an essential connection with Sweden after moving to another EU State and was subject to unlimited tax liability; his reliance on free movement within the EU was rejected.

Updated 2026-11-10. The result is for information only and is not tax or legal advice. Tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes. Consult a qualified adviser before making decisions.

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