Tax residence in Sweden for Pakistani taxpayers

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. Pakistan counts its own tax year of 1 July – 30 June, and a Pakistani citizen can stay resident under s. 82(d) with fewer than 183 days. Where both countries claim you, Art. 4(2) of the 1985 Pakistan–Sweden Convention decides; Pakistan relieves double tax by a credit, Sweden by a credit or, for active business income earned in Pakistan, by exemption (Art. 23).

Check your status: Pakistan and Sweden

Free, no sign-up, about 3 minutes. Conclusion under Pakistan's Income Tax Ordinance, 2001, 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 Pakistani tax rules

Collision: a permanent stay in Sweden while Pakistan also treats you as resident. 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. Pakistan may treat you as resident at the same time: with 183 days in its tax year, as a government employee posted abroad (s. 82(c)) or, if you are a Pakistani citizen, under s. 82(d) — and six months in Sweden spread over two Pakistani tax years can leave you with no more than 182 days in Sweden in each, so a citizen stays resident in Pakistan. Art. 4(2) of the Pakistan–Sweden Convention decides: a permanent home in only one country — that country; a home in both — the centre of vital interests; if that cannot be determined or you have no permanent home in either — habitual abode; then nationality; then mutual agreement. Under s. 107 the treaty prevails over the Ordinance.
Collision: you live in Sweden while Pakistan also treats you as resident. 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. In the same Pakistani tax year you may still be resident in Pakistan — with 183 days there before you left, or as a citizen under s. 82(d) if you spent no more than 182 days in Sweden in that tax year. 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 — family, work, assets and social ties.
Collision: an essential connection with Sweden after moving to Pakistan. 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 Pakistan and are resident there, both countries tax your worldwide income. Art. 4(2) of the Convention decides: if your only permanent home is in Pakistan, you are a resident of Pakistan for the treaty, and Sweden may tax only what the Convention allows — for example pay for work in Sweden, Swedish real property, and under Art. 21(3) other income arising in Sweden, such as Swedish pensions and, according to the Swedish guidance, gains on shares. Pakistan credits the Swedish tax up to the Pakistani tax on that income (Art. 23(1); s. 103).
Collision: Pakistani citizen resident in both countries. Since tax year 2023, s. 82(d) of the Income Tax Ordinance treats a Pakistani citizen as resident in Pakistan if he or she was not present in any other country for more than 182 days in the Pakistani tax year, or is not a resident taxpayer of any other country. Sweden can treat you as resident because you live there, stay there six months in a row or keep an essential connection — none of which needs 183 days in a Pakistani tax year. If both apply, Art. 4(2) of the Convention decides; your Pakistani citizenship counts only at the nationality step. If the treaty makes you a resident of Sweden, Pakistan may tax you only on Pakistan-source income as the treaty allows. Keep evidence of your home and ties and a day count for both periods.

What else to know

Which treaty applies: the Pakistan–Sweden Convention (1985). The Convention between Sweden and Pakistan signed at Islamabad on 22 December 1985 has been in force since 30 June 1986 and applies to income from 1 January 1987 (Art. 29); it replaced the 1958 agreement. Residence tie-breaker: Art. 4(2) — permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement; a person liable to tax in a State only on income from sources there is not its resident (Art. 4(1)). Employment: Art. 16 (183 days in any twelve month period); independent services: Art. 15; directors and top-level managers: Art. 17; government service: Art. 19. There is no pension article: pensions and social security benefits fall under Art. 21 (other income), which lets the State where they arise tax them as well. Relief: Art. 23 — Pakistan gives a credit; Sweden gives a credit but exempts active business income earned in Pakistan through a permanent establishment or fixed base. Mutual agreement: Art. 25. Sweden lists the Convention under the MLI, but the MLI has not taken effect for it, and Sweden's reservations exclude the MLI rules on residence and relief anyway. Under s. 107 of the Ordinance the treaty prevails in giving relief.
Different counting: 183 days from 1 July, six months in a row in Sweden. Pakistan counts days in its tax year (1 July – 30 June) and makes you resident with 183 days (s. 82(a)). Sweden has no 183-day test: a stay of at least six months in a row is a permanent stay (stadigvarande vistelse) 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; Sweden taxes by calendar year. The treaty's 183-day test for employees (Art. 16(2)(a)) uses any twelve month period. The same stay can therefore give three different counts — keep a record of your days for each.
Year of moving: Sweden splits the year, Pakistan does not. 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. Pakistan decides your status for its whole tax year (1 July – 30 June). A Pakistani citizen who leaves during a tax year and stays abroad for the rest of it is exempt in Pakistan on salary earned abroad in that year (s. 51(2)); a citizen who returns after four non-resident tax years is exempt on foreign-source income in the year of return and the next (s. 51(1)). Where the two periods overlap, the treaty decides; if you are taxed against the treaty, present the case to the competent authority within three years (Art. 25).
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 resident in Pakistan under the treaty, Sweden may not tax it if all conditions of Art. 16(2) are met: no more than 183 days in Sweden in any 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). Otherwise Sweden taxes the pay; in Pakistan that salary is exempt under s. 102 if the Swedish tax was withheld and paid, otherwise Pakistan gives a credit (Art. 23(1), s. 103). Self-employed: Sweden may tax income from a fixed base in Sweden, from a stay of 183 days or more in any twelve month period, or remuneration paid by a Swedish resident or borne by a Swedish permanent establishment or fixed base that exceeds SEK 60,000 in the fiscal year (Art. 15(1)). Board fees from a Swedish company and pay of a top-level manager of a Swedish company may be taxed in Sweden regardless of days (Art. 17).
How double tax is relieved between Pakistan and Sweden. If you are resident in Pakistan, Swedish tax on income from Swedish sources taxed in both countries is credited against Pakistani tax on that income, subject to Pakistani law and up to the share of Pakistani tax attributable to it (Art. 23(1)); under s. 103 the limit is computed separately for each head of income and unused credit is lost; salary for work in Sweden on which Swedish tax was withheld and paid is exempt in Pakistan (s. 102). If you are resident in Sweden, Sweden deducts the Pakistani tax on income that Pakistan may tax under the treaty — but not additional tax for late deposit or penalties (Art. 23(2)(a)); income of a permanent establishment or fixed base in Pakistan whose income comes mainly from active business there, and Pakistani government pay and pensions taxable only in Pakistan, are exempt in Sweden but count for the rate (Art. 23(2)(b)–(c)). The tax-sparing credit for Pakistani incentives applied only for the first ten years of the Convention.
Swedish resident working in Pakistan: the six-month rule. If you are subject to unlimited tax liability in Sweden and work as an employee in Pakistan for at least six months, Sweden does not tax that pay to the extent it was taxed in Pakistan (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. Otherwise Sweden taxes the pay and deducts the Pakistani tax (Art. 23(2)(a)). Self-employed: income from a fixed base in Pakistan that comes mainly from active work there is exempt in Sweden with progression (Art. 23(2)(b)–(c)); other independent income — credit.
Pakistani government posting to Sweden. Federal and Provincial Government employees and officials posted abroad remain resident in Pakistan under s. 82(c). Under Art. 19(1) of the treaty their government pay is taxable only in Pakistan; Sweden may tax it only if the services are rendered in Sweden by a Swedish resident who is a Swedish national or did not become resident in Sweden solely to render the services.
Pensions: no pension article — both countries may tax. The Pakistan–Sweden Convention has no article on private pensions. Pensions, social security benefits and annuities are «other income» under Art. 21: taxable in the country of residence, but the country where they arise may also tax them (Art. 21(3)). A Swedish pension paid to a resident of Pakistan is therefore subject to SINK of 22.5% (20% from 2027), with a tax-free SEK 3,799 a month on State pensions; if Pakistan also taxes it, Pakistan credits the Swedish tax (Art. 23(1), s. 103). A pension from Pakistan paid to a Swedish resident is taxed in Sweden with a deduction for any Pakistani tax (Art. 23(2)(a)). Government pensions follow Art. 19(2): taxable only in the paying country, unless you are both resident in and a national of the other country; Sweden then exempts a Pakistani government pension with progression (Art. 23(2)(c)).
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. The relief lowers only Swedish tax; it does not change which country is your residence under the treaty.
Leaving Sweden for Pakistan: essential connection and the ten-year rule. 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). The Pakistan–Sweden Convention does not deal with such gains in Art. 14, so Art. 21 applies: the Swedish guidance treats gains on shares as income that Sweden may tax where it arises (Art. 21(3)); Pakistan then credits the Swedish tax if it taxes the gain (Art. 23(1), s. 103). If you are a Pakistani citizen returning after four non-resident tax years, foreign-source income is exempt in Pakistan in the year of return and the next (s. 51(1)).
Certificates of residence and tax paid. To claim treaty benefits in Sweden as a resident of Pakistan — for example the Art. 16(2) exemption — apply to the Competent Authority of Pakistan (FBR, Islamabad) for a certificate of residence under rule 19A; a separate certificate is needed for each tax year. If you are resident in Sweden and tax was deducted in Pakistan, the Competent Authority can certify the tax paid for your Swedish deduction (rule 19B).

How dual residence is resolved

If both countries treat you as a resident, Art. 4(2) of the treaty applies: Convention between the Kingdom of Sweden and the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, with Protocol, signed at Islamabad on 22 December 1985 (Sweden: Lag (1986:595); SÖ 1986:43). The tests are applied in order — permanent home, centre of vital interests, habitual abode, nationality, and finally mutual agreement between the tax authorities.

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

Is there a tax treaty between Pakistan and Sweden?

Yes. The Convention signed at Islamabad on 22 December 1985 has been in force since 30 June 1986 and applies to income from 1 January 1987 (Art. 29). Its tie-breaker for individuals is Art. 4(2): permanent home, centre of vital interests, habitual abode, nationality, then mutual agreement.

I work in Sweden for a few months. Does Sweden tax my salary?

If you are resident in Pakistan under the treaty, Sweden does not tax the salary only if you were present no more than 183 days in any twelve month period, your employer is not resident in Sweden and no Swedish permanent establishment or fixed base bears the pay (Art. 16(2)). Otherwise Sweden taxes it — for non-residents by SINK of 22.5% in 2026 (20% from 2027) — and in Pakistan that salary is exempt under s. 102 if the Swedish tax was withheld and paid.

I live in Pakistan. Can Sweden tax my Swedish pension?

Yes. The Convention has no pension article, so pensions and social security benefits are «other income» under Art. 21, which lets the country where they arise tax them as well (Art. 21(3)). Sweden levies SINK on Swedish pensions of non-residents, with a tax-free SEK 3,799 a month on State pensions; if Pakistan also taxes the pension, it credits the Swedish tax (Art. 23(1), s. 103).

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).
Convention between the Kingdom of Sweden and the Islamic Republic of Pakistan for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, signed at Islamabad on 22 Dec 1985 (SÖ 1986:43; Sweden: Lag (1986:595)), Art. 29 — The Convention enters into force on the later of the dates on which the Governments notify each other that their constitutional formalities are complete, and has effect for taxes withheld at source on amounts paid or remitted to non-residents on or after 1 January of the calendar year following entry into force, and for other taxes on income derived on or after that date; the 1958 agreement between Pakistan and Sweden then ceases to have effect. Entry into force: 30 Jun 1986, after an exchange of notes (SÖ 1986:43; Förordning (1986:732)) — so it applies from 1 Jan 1987.
Art. 4(1)–(2) Pakistan–Sweden Convention (1985) — (1) A resident of a State is a person liable to tax there by reason of domicile, residence, place of management or any similar criterion — not a person liable to tax there only on income from sources in that State. (2) Dual-resident individual: (a) 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); (b) if the State of the centre of vital interests cannot be determined, or if he has not a permanent home available to him in either State — the State in which he has an habitual abode; (c) habitual abode in both States or in neither — the State of which he is a national; (d) national of both or of neither — the competent authorities settle the question by mutual agreement.
Sweden — MLI position at deposit (22 Jun 2018), list of Covered Tax Agreements, No. 45 (Pakistan) — Sweden lists the Pakistan–Sweden Convention as a Covered Tax Agreement. Sweden reserved the whole of MLI Art. 4 (dual-resident entities) and Art. 5 (methods for elimination of double taxation) for all its Covered Tax Agreements, and under its Art. 35(7)(a) reservation the MLI takes effect for a treaty only after Sweden notifies completion of its internal procedures for it.
Income Tax Ordinance, 2001, s. 107(2) — Subject to s. 109, a double taxation agreement and its implementing notification have effect notwithstanding anything in any other law, so far as they provide relief from tax under the Ordinance, determine the Pakistan-source income of non-residents, or provide for exchange of information.
Income Tax Ordinance, 2001, s. 82(a) — An individual is a resident individual for a tax year if present in Pakistan for a period of, or periods amounting in aggregate to, 183 days or more in the tax year (1 July – 30 June).
Art. 16(1)–(2) Pakistan–Sweden Convention (1985) — Subject to Arts. 17, 19 and 20, pay of a resident of one State for employment exercised in the other State may be taxed in that other State. It is taxable only in the State of residence if (a) the recipient is present in the other State for a period or periods not exceeding in the aggregate 183 days in any twelve month period, (b) the pay is paid by, or on behalf of, an employer who is not a resident of the other State, and (c) it is not borne by a permanent establishment or fixed base which the employer has in the other State.
Income Tax Ordinance, 2001, s. 82(d) (inserted by the Finance Act, 2022; FBR consolidated text amended up to 30.06.2026) — Resident individual: one who, being a citizen of Pakistan, is not present in any other country for more than one hundred and eighty-two days during the tax year or who is not a resident taxpayer of any other country.
Art. 21 Pakistan–Sweden Convention (1985) (other income) — (1) Items of income of a resident of a State not dealt with in the foregoing Articles are taxable only in that State. (2) This does not apply to income effectively connected with a permanent establishment or fixed base in the other State (Art. 7 or 15 applies). (3) Notwithstanding (1) and (2), such items of income arising in the other State may be taxed in that other State. The Convention has no separate article on private pensions.
Förordning (1986:732) om dubbelbeskattningsavtal mellan Sverige och Pakistan, bilaga 1 (Swedish guidance to Arts. 14 and 21) — Gains on property other than immovable property, assets of a permanent establishment or fixed base, and ships or aircraft are governed by Art. 21. Under Art. 21(1) income not dealt with elsewhere is taxed only in the State of residence, but under Art. 21(3) income arising in the other State may be taxed there — for example pensions from private employment, benefits under public social insurance, annuities and gains on the sale of shares (to the extent Art. 14(2) does not apply). Sweden taxes such income of its residents arising in Pakistan and deducts the Pakistani tax under Art. 23(2)(a).
Art. 23 Pakistan–Sweden Convention (1985) (elimination of double taxation) — (1) Pakistan: subject to Pakistani law on credits, Swedish tax payable, directly or by deduction, by a resident of Pakistan on income from sources within Sweden taxed in both States is allowed as a credit against Pakistan tax on that income, up to the proportion of Pakistan tax that this income bears to the entire income chargeable to Pakistan tax. (2) Sweden: (a) deducts from Swedish tax the Pakistan tax paid on income that Pakistan may tax under the Convention, subject to Swedish law — not additional tax for late deposit or penalties; (b) exempts income of a permanent establishment or fixed base in Pakistan (Art. 7 or 15(1)(a)) if its principal part arises from business activities, other than managing securities and similar property, carried on in Pakistan; (c) exempts income taxable only in Pakistan under Arts. 8(1), 14(3) and 19(1)–(2), and income exempt under (b), but may take it into account for the rate on the remaining income; (d) tax-sparing credit for Pakistani incentives — only for the first ten years of the Convention.
Income Tax Ordinance, 2001, s. 51 — (1) A citizen who becomes resident in a tax year after being non-resident in the four preceding tax years: foreign-source income is exempt in that tax year and the following one. (2) A citizen who leaves Pakistan during a tax year and remains abroad for the rest of it: salary earned outside Pakistan in that year is exempt.
Art. 25(1) Pakistan–Sweden Convention (1985) — A person who considers that the actions of one or both States result or will result in taxation not in accordance with the Convention may, irrespective of domestic remedies, present the case to the competent authority of the State of which he is a resident (or, under Art. 24(1), of which he is a national) within three years from the first notification of the action.
Art. 15(1) Pakistan–Sweden Convention (1985) — Income from professional services or other independent activities is taxable only in the State of residence, except that it may also be taxed in the other State (a) if the person has a fixed base regularly available to him there — only the income attributable to it; (b) if his stay there amounts to or exceeds in the aggregate 183 days in any twelve month period — only the income from activities performed there; or (c) if the remuneration for his activities there is paid by a resident of that State or borne by a permanent establishment or fixed base situated there and exceeds SEK 60,000 (or its equivalent in Pakistan currency) in the fiscal year.
Art. 17 Pakistan–Sweden Convention (1985) — Directors' fees of a resident of one State as a member of the board of directors of a company resident in the other State, and salaries of an official in a top-level managerial position of such a company, may be taxed in the company's State.
Income Tax Ordinance, 2001, s. 102 — Foreign-source salary received by a resident individual is exempt if the individual has paid foreign income tax on it; tax is treated as paid if it was withheld by the employer and paid to the revenue authority of the country where the employment was exercised.
Income Tax Ordinance, 2001, s. 103 — A resident taxpayer gets a credit for foreign income tax on foreign-source income equal to the lesser of the foreign tax paid and the Pakistan tax on that income (average Pakistani rate × net foreign-source income), computed separately for each head of income; unused credit is not refunded, carried back or forward; the foreign tax must be paid within two years after the end of the tax year.
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.
Income Tax Ordinance, 2001, s. 82(c) — An individual is a resident individual for a tax year if he or she is an employee or official of the Federal Government or a Provincial Government posted abroad in the tax year — regardless of days in Pakistan.
Art. 19 Pakistan–Sweden Convention (1985) — (1) Remuneration, other than a pension, paid by a State, its political subdivision or local authority for services rendered to it is taxable only in that State; but only in the other State if the services are rendered there and the individual is a resident of that State who is its national or did not become a resident solely for the purpose of the services. (2) A pension paid by, or out of funds created by, a State, subdivision or authority for such services is taxable only in that State; but only in the other State if the individual is a resident and a national of that other State. (3) Pay and pensions for services in connection with a business carried on by the State fall under Arts. 16 and 17.
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.
Income Tax Rules, 2002, rule 19A — A resident who needs a certificate of residence for a treaty country applies to the Competent Authority of Pakistan (FBR, Islamabad) in the prescribed form with proof of foreign income, CNIC, NTN and the latest return; a separate application and certificate for each tax year; decision within 45 days.
Income Tax Rules, 2002, rule 19B — A non-resident may apply to the Competent Authority of Pakistan for a certificate of tax paid in Pakistan (by deduction, collection or otherwise) for presentation to the tax authority of the country of residence; proof of residence in that country is required.
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(2)(a) Pakistan–Sweden Convention (1985) — 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) Pakistan–Sweden Convention (1985) — 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 State, he is deemed to be a resident of the State in which he has an habitual abode.
Art. 4(2)(c), (d) Pakistan–Sweden Convention (1985) — 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 national (c); if he is a national 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), 30/05/2018 — 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), 30/05/2018 — 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), 30/10/2019 — 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), 30/10/2019 — 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), 25/03/2024 — 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, 08/06/2020 — 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), 20/03/2019 — 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), 22/10/2020 — 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 10/11/2026. The result is for information only and is not tax or legal advice. The FBR, other tax authorities and courts may interpret the rules differently, including because of circumstances not covered here, and the law changes with each Finance Act. Consult a qualified adviser before making decisions.

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