DoubleTaxationUnited States – Sweden tax treaty: residence, 183 days, rates
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))
- Signed: 1994-09-01
- In force since: 1995-10-26
- Official text
If both countries treat you as resident
- 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. 4(1)(b) of the Sweden–United States Convention (as replaced by Art. III of the 2005 Protocol)
- 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)(a) 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)(b) 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). Art. 4(2)(c), (d) of the Sweden–United States Convention (1994/2005)
Income: who taxes it
| Income | Treaty rule | Article |
|---|---|---|
| Salary (employment) | The country where the work is done may tax it. Exempt if all apply: no more than 183 days in any 12-month period; the employer is not resident there; the pay is not borne by its permanent establishment there. | Art. 15(2) |
| Self-employment, business, services | Country of residence; the other country only taxes profits of a permanent establishment (fixed base) there. | Art. 7, Art. 14 |
| Pension | Only the country of residence. | Art. 19(1)-(2) |
| State pension (social security) | Only the source country (for pensions, the paying country). | Art. 19(1)-(2) |
| Government service | Usually only the paying country; exception: service in the other country by its national. | Art. 20(1)-(2) |
| Government service pension | Usually only the paying country; exception: service in the other country by its national. | Art. 20(1)-(2) |
| Rent from real estate | The country where the property is located may tax; the country of residence relieves double taxation. | Art. 6(1) |
| Dividends | Source country: at most 15%; the country of residence relieves double taxation. | Art. 10(2)(b) |
| Interest (deposits, bonds, loans) | Only the country of residence. | Art. 11(1) |
| Royalties (copyright, licences) | Only the country of residence. | Art. 12(1) |
| Sale of property or shares | Real estate: the country where it is located may tax. Shares of companies deriving their value mainly from real estate: the same. Other property: under certain conditions the source country may also tax (see the article). | Art. 13 |
| Other income | Only the country of residence. | Art. 22(1) |
How double taxation is relieved
- Sweden: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(2)-(4)
- United States: credit for the tax paid in the source country, up to the country’s own tax on that income Art. 23(1), (3)-(4)
Data checked: 2026-11-10. A short summary for individuals; the full conditions, exceptions and protocols are in the treaty text. General information, not legal advice.